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oA,^i i-RANCiaoo PUBLIC LISR^af" 

SAN FRANCISCO j 
PUBLIC LIBRARY | 

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REFERENCE 

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San Frsincisco Planning Department 



SAN FRANCISCO 
SOUTHERN WATERFRONT 

Final Supplemental 
Environmental Impact Report 

Planning Department Case No. 1999.377E 
State Clearinghouse No. 94123007 

Draft SEIR Publication Date: September 23, 2000 
Draft SEIR Public Hearing Date: October 26, 2000 
Draft SEIR Public Comment Period: September 23 to November 7, 2000 

SEIR Certification Date: February 15, 2001 

DOCUMENTS DEPT. 

MAR 2 3 2001 

SAN FRANCISCO 
PUBLIC LIBRARY 

Changes from the text of the Draft SEIR are indicated by a line ( I ) in the margin. 
Each new page and each new or revised graphic or table is indicated by a dot (•). 




GOVERNMENT INFORMATION CENTER 
SAN FRANCISCO PUBUC UBRARY 
C']VIC CENTER 
SAN FAMMCISCO. CAUFORNIA 94.1 OS 

SAN FRANCISCO 
PUBLIC LIBRARY 

REFERENCE 
BOOK 



/Mo I lo he Idkcii Jroin I he Lihiriry 



APR 2 7 2001 



SAN FRANCISCO PUBLIC LIBRARY 




SAN FRANCISCO 
PLANNING COMMISSION 
MOTION NO. 16093 



ADOPTING FINDINGS RELATED TO THE CERTIFICATION OF A FINAL 
SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT FOR THE PROPOSED SAN 
FRANCISCO SOUTHERN WATERFRONT PROJECT LOCATED GENERALLY IN SAN 
FRANCISCO PORT JURISDICTION FROM PIER 70 SOUTH TO INDIA BASIN. 



MOVED, That the San Francisco Planning Commission (hereinafter "Commission") hereby 
CERTIFIES the Final Supplemental Environmental Impact Report identified as Case File No. 1999.377E, 
(hereinafter "Project") based upon the following findings: 

1) The City and County of San Francisco, acting through the Planning Department (hereinafter 
"Department") fulfilled all procedural requirements of the California Environmental Quality Act (Cal. 
Pub. Res. Code Section 21000 et seg., hereinafter "CEQA"), the State CEQA Guidelines (Cal. Admin. 
Code Title 14, Section 15000 et. seg., (hereinafter "CEQA Guidelines") and Chapter 31 of the San 
Francisco Administrative Code (hereinafter "Chapter 31"). 

a. The Department determined that a Supplement to the Waterfront Land Use Plan EIR, Case 
No. 94.155E, was required and provided public notice of that determination by publication in a 
newspaper of general circulation on June 12, 2000. 

b. On September 23, 2000, the Department published the Draft Supplemental Environmental 
Impact Report (hereinafter "DSEIR") and provided public notice in a newspaper of general circulation of 
the availability of the DSEIR for public review and comment and of the date and time of the Commission 
public hearing on the DSEIR on Thursday, October 26, 2000. This notice was mailed to the Department's 
list of persons requesting such notice. 

c. Notices of availability of the DSEIR and of the date and time of the public hearings were 
posted near the Project site by Department staff on or about September 22, 2000. 

d. On September 22, 2000, copies of the DSEIR were mailed or otherwise delivered to a list of 
persons requesting it, to those noted on the distribution list in the DSEIR, to adjacent property owners, 
and to government agencies. 

2) The Commission held a duly advertised public hearing on said DSEIR on October 26, 2000, at 
which opportunity for public comment was given, and public comment was received on the 
DSEIR. The period for acceptance of written comments ended on November 7, 2000. 



FrONO 



Case File No.: 1999.377E 
Southern Waterfront 
Motion No: 16093 
Page 2 

3) The Department prepared responses to comments on environmental issues received at the public 
hearings and in writing during the 45 -day public review period for the DSEIR, prepared revisions to the 
text of the DSEIR in response to comments received or based on additional information that became 
available during the public review period, and corrected errors in the DSEIR. This material was presented 
in a "Draft Sunmiary of Comments and Responses," published on January 29, 2001, which was 
distributed to the Commission and to all parties who commented on the DSEIR, and was available to 
others upon request at Department offices. 

4) A Final Supplemental Environmental Impact Report (hereinafter "FSEIR") has been prepared by 
the Department, consisting of the DSEIR, any comments received during the review process, any 
additional information that became available, and the Sunnimary of Conmients and Responses, all as 
required by law. 

5) Project Environmental Impact Report files have been made available for review by the 
Commission and the public. These files are available for public review by appointment at the Planning 
Department offices, and are part of the record before the Commission. 

6) On February 15, 2001, the Commission reviewed and considered the FSEIR and found that the 
contents of said report and the procedures through which the FSEIR was prepared, publicized, and 
reviewed comply with the provisions of CEQA, the CEQA Guidelines, and Chapter 31 of the San 
Francisco Administrative Code. 

7) The Commission hereby does find that the FSEIR concerning Case File No. 99.377E reflects the 
independent judgment of the City and County of San Francisco; is adequate, accurate and objective; and 
that the Summary of Comments and Responses contains no significant revisions to the DSEIR; and 
hereby does CERTIFY THE COMPLETION of said FSEIR in compliance with CEQA and the CEQA 
Guidelines. 

8) The Commission, in certifying the completion of said FSEIR, hereby does find that the Project 
described in the Environmental Impact Report will result in significant, unmitigable traffic congestion at 
selected local intersections, and will result in total projected emissions of criteria pollutants on a region- 
wide basis that would exceed BAAQMD project-specific significance standards. Also, while project- 
specific impacts on local air quality would be less than significant they would contribute to potentially 
significant cumulative air emissions from existing and possible future sources in the greater site vicinity. 

9) The Commission, in certifying the completion of said FSEIR, acknowledges the health issues 
experienced by the Bayview - Hunter Point residents, and finds that the FSEIR considers this issue and 
requests that the decision makers, in this case the Port Commission and Board of Supervisors, give 
careful consideration to this issue in evaluating the project and in the implementation and monitoring of 
effective mitigation measures. The following sections of the FSEIR warrant particular attention: 

• existing health concerns on pp. 77-78 

• air quality and dust control mitigation measures on pp. 146-149 

• stormwater runoff mitigation measures on pp. 149-150 
— • diesel emission mitigation measures on p. 147 



Case File No.: 1999.377E 
Southern Waterfront 
Motion No: 16093 
Page 3 



I hereby certify that the foregoing Motion was ADOPTED by the City Planning Commission at its 
regular meeting of February 15, 2001. 

Linda Avery 
Commission Secretary 

AYES: Commissioners Theoharis, Baltimore, Fay, Joe and Salinas 

NOES: None 

ABSENT: Chinchilla 

ADOPTED: February 15,2001 



3 1223 05770 0081 



San Francisco Planning Department 



SAN FRANCISCO 
SOUTHERN WATERFRONT 

Final Supplemental 
Environmental Impact Report 



Planning Department Case No. 1999.377E 
State Clearinghouse No. 94123007 

Draft SEIR Publication Date: September 23, 2000 
Draft SEIR PubUc Hearing Date: October 26, 2000 
Draft SEIR Public Comment Period: September 23 to November 7, 2000 

SEIR Certification Date: February 15, 2001 



Changes from the text of the Draft SEIR are indicated by a line ( I ) in the margin. 
Each new page and each new or revised graphic or table is indicated by a dot (•). 



This report has been printed on post-consumer recycled paper/ESA 990267 



TABLE OF CONTENTS 



SOUTHERN WATERFRONT PROJECT 

FINAL SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT 



Page 



INTRODUCTION iv 

I. SUMMARY S-1 

II. PROJECT DESCRIPTION 1 

A. Site Location 1 

B. Project Sponsor's Objectives 1 

C. Project Characteristics and Approval Requirements 4 

III. ENVIRONMENTAL SETTING AND IMPACTS 25 

A. Land Use 25 

B. Transportation 44 

C. Air Quality 63 

D. Hydrology and Water Quality 99 

E. Hazardous Materials 114 

F. Biological Resources 136 

G. Growth Inducement 141 

IV. MITIGATION MEASURES PROPOSED TO MINIMIZE 143 

THE POTENTIAL ADVERSE IMPACTS OF THE PROJECT 

V. SIGNIFICANT ENVIRONMENTAL EFFECTS THAT CANNOT BE 165 
AVOIDED IF THE PROPOSED PROJECT IS IMPLEMENTED 

I VL ALTERNATIVES TO THE PROPOSED PROJECT 167 

A. No Project 168 

B. Reduced-Scale Alternative 169 

C. Residential Use Future Scenario 172 

VII. DRAFT SEIR DISTRIBUTION LIST 175 
I VIH. SUMMARY OF COMMENTS AND RESPONSES C&R.l 



I IX. APPENDICES 

I X. EIR AUTHORS AND CONSULTANTS 



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Page 

LIST OF FIGURES 

1. Project Location 2 

2. Project Components (Revised) 8 

3. Existing and Proposed Freight Rail Routes 21 

4. Generalized Map of Existing Land Uses 26 

5. Intersection Levels of Service 55 

6. Annual Wind Rose, Potrero Power Plant (1991-1992) 65 

7. Sensitive Receptors (Revised) 92 

LIST OF TABLES 

1. Project Characteristics (Revised) 6 

2. Phase I Project Trip Generation (2003) 50 

3. Phase 11 Project Trip Generation (2015) 5 1 

4. Traffic Level Of Service Results 53 

5. Phase II Project Transit Trip Generation (2015) 59 

6. Phase II Parking Demand and Requirement (2015) 61 

7. State and National Criteria Air Pollutant Standards, Effects, and Sources 66 

8. Summary of Local Monitoring Data for the Arkansas Street 74 

and Ellis Street Stations, 1995-1999 

9. Summary of Regional Monitoring Data for the San Francisco 75 

Bay Area Air Basin, 1995-1999 

10. San Francisco, Arkansas Street Station, Toxic Air Contaminant Concentrations, 1994-1998 76 

11. Estimated Net Change in Regional Pollutant Emissions, 2003 and 2015 84 

12. Estimated Net Change in Daily Regional Pollutant Emissions by Project Component, 2003 85 

13. Estimated Net Change in Annual Regional Pollutant Emissions by Project Component, 2003 86 

14. Estimated Net Change in Daily Regional Pollutant Emissions by Project Component, 2015 87 

15. Estimated Net Change in Annual Regional Pollutant Emissions by Project Component, 2015 88 

16. Estimated Carbon Monoxide Concentrations at Selected Intersections in Project Vicinity 90 

17. Maximum PM-10 Concentrations at Sensitive Receptors 94 

18. Maximum Diesel Particulate Concentrations and Risk at Sensitive Receptors 95 

19. Estimated Change in Impervious Surface due to Project Components 107 

20. Changes in Stormwater Flow and Combined Sewer Overflows 110 

21. Summary of Potential Hazardous Materials Site Conditions 120 

at Industry Group Project Sites 

22. Summary of Potential Hazardous Materials Site Conditions 124 

at Future Port Development Sites 

23. Mitigation Measures For Intersection Levels of Service 144 

24. Traffic Levels of Service for Alternative B 171 

25. Traffic Levels of Service for Alternative C 174 



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INTRODUCTION 



On January 9, 1997, the San Francisco Planning Commission certified a Final EIR, Port of 
San Francisco Waterfront Land Use Plan EIR (Case No. 94.155E; State Clearinghouse No. 94123007), 
for the adoption by the Port of San Francisco of a plan governing future uses and development within the 
Port's approximately 7.5 miles of jurisdiction, covering the San Francisco waterfront generally from the 
Hyde Street Pier to India Basin. That FEIR is referred to herein as the "Waterfront Plan FEIR." 

Subsequent to completion of the Waterfront Plan FEIR, the San Francisco Port Commission in June 1997 
adopted the Waterfront Land Use Plan ("the Waterfront Plan"), which specifies acceptable and 
unacceptable land uses for all properties under Port jurisdiction, and is intended to guide future 
development of Port properties and to satisfy requirements of Proposition H, passed in November 1990. 
The Waterfront Plan allows for new development on Port property, with a mixture of maritime and 
commercial uses anticipated generally north of China Basin and predominantly maritime expansion from 
Pier 70 south, in the subarea known as the Southern Waterfront. Short-term, "interim" uses are also 
allowed that do not preclude the ultimate reuse of land on the Southern Waterfront for maritime 
purposes. The Waterfront Plan identified a number of "mixed-use opportunity areas" that were 
anticipated to be the location of future developments including maritime uses, open space, public access, 
and certain commercial and recreational uses, potentially in close proximity to other nearby uses on non- 
Port property. Three of these opportunity areas are located within the Southern Waterfront - at Pier 70; 
at the former Western Pacific rail yard between 25th and Cesar Chavez (Army) Streets, east of Illinois 
Street; and northeast of Cargo Way in the "backlands" west (inland) of the South Container Terminal at 
Piers 94-96. 

Since publication of the Waterfront Plan EIR, the Port has received inquiries from a number of potential 
maritime-industrial and general industrial users seeking to lease land within Port jurisdiction in the 
Southern Waterfront. Upon preliminary review of the lease applications, Port staff, in consultation with 
Planning Department staff, determined that, while the proposed uses would be consistent with the 
Waterfront Plan direction for the Southern Waterfront, the Waterfront Plan FEIR did not analyze such 
uses. Beyond these projects, collectively described in this SEIR as the Industry Group project 
components, the Port itself has proposed construction of a rail and truck bridge over Islais Creek at 
Illinois Street to provide access to and between the North and South Container Terminals at Pier 80 and 
Piers 94-96, respectively. Additionally, the Port anticipates future growth in cargo shipping activity at 
Pier 80 and Piers 94-96, as well as potential future development of maritime and non-maritime activities 
on the three opportunity areas noted above. 



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In addition, since certification of the Waterfront Plan EIR, there have been changes in the regulatory 
environment with respect to air quality, in that the San Francisco Bay Area Air Basin first achieved, and 
then lost, "attainment" status for the national ozone standard, and achieved attainment status for the state 
and national carbon monoxide standards; the Bay Area remains in "non-attainment" status for the state 
ozone and PM-10 standards, meaning that the Bay Area violates these state standards with some 
regularity. In addition, in 1998, the California Air Resources Board designated particulate emissions 
from diesel-fueled engines as a toxic air contaminant, resulting in increased concern regarding diesel 
emissions. 

In light of the above, this Supplemental EIR (SEIR) has been prepared to analyze potential transportation 
and air quality effects related to the Industry Group project components, the proposed Illinois Street 
Intermodal Bridge, and potential future increases in cargo shipping and development in the mixed-use 
opportunity areas. Note, however, that no changes are proposed in the Waterfront Plan to accommodate 
the Industry Group components or the Illinois Street bridge. 

In addition to transportation and air quality, this SEIR includes a discussion of land use, plans, and 
policies, and analyzes effects related to runoff and water quality that could result from development of 
the Industry Group and opportunity area sites, and effects on biological resources that could result from 
construction of the Islais Creek bridge. Finally, this SEIR reviews and updates the Waterfront Plan 
FEIR's analysis of potential effects related to hazardous materials and site contamination. Effects for 
topics other than those iterated above would not be expected to differ substantively from those analyzed 
in the Waterfront Plan FEIR, and no new analysis is required. 



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CHAPTER I 



SUMMARY 

A. PROJECT DESCRIPTION (p. 1) 

This SEIR analyzes a series of development proposals - the "Industry Group" project components - in 
the portion of the Port of San Francisco jurisdiction known as the Southern Waterfront (generally. 
Pier 70 south to India Basin and east of Illinois Street). This SEIR also analyzes a Port-sponsored • 
proposal to construct a rail and truck bridge across Islais Creek to improve access between the Port's 
major maritime terminals. Finally, this SEIR evaluates, at a lesser level of detail, potential future 
development on other Port lands in the Southern Waterfront to provide a conservative SEIR analysis, 
although there are no such proposed projects at this time. 

INDUSTRY GROUP COMPONENTS 

Six private entities (one combining two separate companies, or seven operators in total) have proposed 
leasing portions Of the Port of San Francisco's Southern Waterfront area and implementing development 
proposals, primarily related to the construction industry. Each of these Industry Group project 
components would involve a project sponsor leasing property from the Port and making improvements 
on the leased site. In most cases, the lease would involve unimproved land that the sponsor would 
develop. In some cases, the individual sponsors would occupy one or more existing buildings on Port 
property with lease provisions for tenant-financed improvements to such buildings. Each Industry Group 
component is briefly described here. All of the Industry Group components are expected to be 
constructed and operational in 2001. 

Bode Gravel / Mission Valley Rock. This comporient of the project would consist of two adjacent 
facilities to be developed at Pier 92. Bode Gravel Company would develop a ready-mix concrete plant 
and Mission Valley Rock Company would develop a marine terminal to import aggregate materials 
(gravel and crushed rock) for use in production of concrete. In addition, Mission Valley Rock is 
pursuing discussions with the Port to develop an asphalt plant, which would also use imported aggregate 
materials. Although the Port has not indicated any affirmative interest in development of an asphalt 
plant, the potential impacts of such an operation are included in this EIR analysis. The two companies 
would be joint tenants of the Port, occupying a total area of 8.2 acres, although ownership and operations 
of the two facilities would be separate. 

Bode currently operates a ready-mix concrete plant at Third and Sixteenth Streets, within the Mission 
Bay area now under development, and would dismantle this plant and construct a new facility at Pier 92. 



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The new Bode ready-mix plant would have the same capacity as the existing plant. It would be at the 
east end of Amador Street, approximately one-third mile east of Third Street, between an existing 
Mission Valley Rock sand processing plant to the north and a rendering plant to the south. The ready- 
mix plant would include receiving and storage facilities for sand and aggregate material; storage silos for 
Portland cement and "fly ash,"* both of which are used in the production of concrete; a series of 
conveyer belts and pneumatic pumps for movement of the materials throughout the plant; and two 
combined mixers and storage silos, each known as a "batching plant," that would be approximately 
65 feet tall. The plant would employ a "baghouse filter" and Spray bars for dust control. In addition to 
the production facilities, the operation would have a truck maintenance shop, truck washout station with 
water reclamation, an office trailer, and parking for cement mixers and employee vehicles. 

The Mission Valley Rock aggregate import terminal would be located immediately west of the Bode 
concrete plant, dlso on Amador Street, approximately one-quarter mile east of Third Street. As indicated 
previously, Mission Valley Rock is also pursuing discussions with the Port to develop an asphalt plant. 
There are currently no privately owned commercial asphalt plants in San Francisco (the closest is in 
Brisbane). The City operates a plant on Jerrold Avenue for street repairs within San Francisco. Mission 
Valley Rock currently has a sand dredging and processing operation at Pier.92, east of the proposed Bode 
concrete plant, where operations would continue. The proposed asphalt plant would include receiving 
and storage facilities for sand, aggregate, and asphalt cement; an asphalt oil heater and an asphalt drum 
diyer/mixer, both gas-fired; storage bins for the finished asphalt product, which would be dispensed from 
the bins into trucks for delivery to the job site; and conveyors for movement of the materials throughout 
the plant. The dryer/mixer would be equipped with a baghouse filter for dust control. In addition to the 
production facilities, the plant would have an office/control room, a small tool trailer, and employee 
vehicle parking. 

The aggregate terminal would include conveyor systems for transferring aggregate from ships to indoor 
and outdoor storage piles and for transferring aggregate from storage to the proposed asphalt plant and to 
the Bode ready-mix concrete plant, as well as both indoor (in an existing warehouse along the Islais 
Creek waterfront ) and outdoor storage facilities. Mission Valley Rock would use spray bars to sprinkle 
aggregates with water during ship unloading, both at the ship conveyor and at the outdoor stockpile 
where the material would arrive. The entire Mission Valley Rock site would be paved with asphalt of 
concrete. 

British Pacific Aggregates (BPA) would develop a storage facility for the waterbome importation of 
construction aggregates (sand, gravel, and crushed stone) to be used in the production of concrete and 



Ry ash is a powdery material, composed largely of silica, that is captured from the exhaust gas of coal-fired power plants. It 
reacts chemically with the calcium hydroxide in Portland cement and itself becomes cementitious (that is, helps bind the sand 
and aggregate in the concrete). Fly ash is advocated as improving the strength and durability of concrete - although it slows 
the initial curing ^ while at the same time reducing the relative volume of cement needed and thereby reducing the energy 
use and combustion byproducts of cement production. Fly ash is mandated in concrete by both Calttans, for its projects, and 
by the U.S. EPA, for federal projects. One of the Industry Group components would include a fly ash import operation (see 
ISG Resources, p. 14). • . . • 



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asphalt. BPA proposes to use Pier 94 as the dock for ships that would bring aggregate from out-of-state 
to supplement and/or replace existing local supplies. The aggregate would be delivered by self- 
unloading ships directly to Pier 94, where it would be unloaded using on-board equipment and stored in 
stockpiles in up to about six acres on the pier apron (out of a total lease site of about 10 acres), 
approximately 350 feet shoreward of the wharf. To minimize dust, BPA would use spray bars to moisten 
aggregate both during unloading and while in storage. Improvements to be constructed would include 
conveyors to move material from ships to stockpiles and from one location to another and/or for loading 
into trucks for transport to end users. Front-end loader(s) may also be used for loading trucks. No new 
paving would be needed, because the BPA storage facilities would be located on an already-paved 
portion of the Pier 94 apron. : 

In addition to the shipping and storage facilities, BPA has indicated that it may develop a ready-mix 
concrete plant and/or an asphalt plant inland from the stockpile area. Both of these uses are under 
discussion with the Port and have been included in this SEIR for purposes of a conservative analysis. 
These facilities, if constructed, \yould use aggregate material taken directly from the stockpiles (without 
the need to employ diesel haul trucks). Production of ready-inix concrete and/or asphalt by BPA would 
be contingent on the company capturing a share of the local market for one or both products. This SEIR 
does not assume that BPA would engage in production of either product. However, if it does, the net 
rfesult would not be an increase in the total volume of concrete or asphalt manufactured within the 
Southern Waterfront area, but an incremental shift in the location of such production. Should such 
production be undertaken, the concrete and/or asphalt pla:nt(s) would be portable facilities that would be 
erected oh a semi-permanent basis at Pier 94 for the duration of BPA' s lease. Regardless of whether 
concrete or asphalt were produced, no permanent structures would be erected. Other facilities, such as an 
office and tool/repair shop, would be within portable trailers. On-site parking also would be provided. 

ISG Resources Inc. proposes to re-use two existing banks of now- vacant former grain silos at Pier 90 
for the storage of "fly ash," a byproduct of coal-fired power plants that is used as a partial replacement 
for Portlaiid cement in the production of concrete. The silos formerly stored grain that was brought in by 
rail and then loaded from the silos onto ships for export. These operations were discontinued following 
the 1989 Loma Prieta earthquake. Fly ash would be brought in by rail car, transferred to the silos, and 
then made available to concrete producers, including those currently proposing to operate in the 
immediate vicinity - Bode, RMC Pacific, and smaller local producers (and potentially British Pacific). 
In the future, fly ash could be brought by barge from other locations and offloaded into the silos. 
Outbound shipments to concrete batching plants would be in trucks with pneumatic pumping systems. 

Physical improvements to be undertaken on the 2.3-acre site would consist of rehabilitation of the silos; 
enclosure of the conveyor system and installation of state-of-the-art dust control systems on the silos and 
conveyor system; replacement of the electrical and propulsion components for the conveyor system; 
construction of a truck loading facility; and rehabilitation of at least one of the existing rail spurs to allow 
for shipment of fly ash to the ISG site by rail car. Employee parking would be provided on-site. 



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RMC Pacific Materials. RMC Pacific proposes to construct a ready-mix concrete plant on a 3.l7acre 
parcel at the west end of Pier 80, at the southeast comer of Illinois and Marin Streets, to replace its 
existing ready-mix plant at Third and Mariposa Streets, within the Mission Bay project currently under 
development. RMC's existing plant would be dismantled, and the new plant would be developed with 
new equipment. The RMC Pacific site is currently paved and in use as a storage yard by Marine 
' Terminals Corporation, which operates the-Port's North Container Tenninal at Pier 80. RMC proposes 
to receive much of its raw materials - primarily aggregate - by rail and ship. The proposed new ready- 
mix plant would incljude receiving and unloading facilities to, accommodate both rail cars and ships; 
storage bins for aggregate and sand; a 65-foot-tall batching plant with cement and fly ash storage silos, 
mixer, office, and dust containment system; and a series of conveyors for movement of the materials 
throughout the plant. In addition to the production facilities, the ready-mix plant would have a truck 
maintenance shop (involving remodeling of an existing open-bay structure), truck washout station with 
water reclamation, and parking for concrete-mixer trucks and employee vehicles. No on-site truck 
fueling would be provided. RMC mixers would use off-site commercial fueling stations. 

Waste Resources Technologies (WRT), a subsidiary of Waste Management Inc., proposes to operate a 
Construction/Demolition Material Recovery Facility (MRF) in an existing building at Pier 70, in the 
northern portion of the project site. The MRF, which would reclaim usable materials, such as metal and 
wood, contained in construction and demolition debris for recycling, would replace a former WRT 
facility near 3Com Park, which was closed in 1999. 

WRT proposes to lease an existing building at Pier 70, located near 20th and Illinois Streets, in the . 
former Union Iron Works complex. The structure, identified as Building 6, contains approximately 
35,000 square feet of interior space. There would be no structural modifications to the exterior of the 
building, which was constructed in 1941. ' However, WRT would renovate portions of the building's 
interior to accommodate the MRF. WRT would install a sort line with associated screens, conveyors, 

I and other equipment for processing of construction and demoUtion material inside Building 6. In 
contrast to WRT's former outdoor facility at Candlestick Point, all sorting and storage of material would 

I be accomplished within Building 6. Parking would be provided on-site for employee vehicles and for 
staging of semi-trailer transfer trucks. 

Site access would be via 20th and Third Streets. Inbound trucks would come from various' construction 
sites. Outbound trucks would be destined for local processors in the case of recyclable materials and 
• local landfills, such as Redwood Landfill in Marin County and Altamont Landfill in Alameda County, in. 
the case of materials that cannot be reused. Although no waterbome transport of materials is currently 
planned, there is a potential that recyclable materials, such as paper and metals, could be shipped to 
processors through the Port in the future. 

Coach USA proposes to lease approximately 8 acres at Pier 96 for bus storage, maintenance and repair, 
and ancillary office space. Coach USA, through its-subsidiary Grosvenor Bus Lines Inc., currently 
operates Gray Line tour buses, as well as charter bus service, and transit and paratransit service for 



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I. SUMMARY 



transit agencies including Golden Gate Transit and San Mateo County Transit (SamTrans). Grosvenor 
Bus Lines currently operates from a facility at Eighth and Harrison Streets. The company would relocate 
to Pier 96 and vacate its existing Eighth Street operations, where its lease is not being renewed. 

This project component would include use of an existing paved storage yard of approximately 6.9 acres 
(about 300,000 square feet), and use of existing buildings for bus maintenance and repair building (about 
26,000 square feet), office space (about 11,500 square feet), and additional miscellaneous building space 
(about 4,000 square feet). Coach USA plans to construct a fuel island and diesel fuel storage tank and a 
bus washer. The company also proposes to make some improvements to the buildings that would be 
used for maintenance/repair and office space. On-site parking for employees and buses would be 
provided. Buses would enter and leave Pier 06 via Cargo Way. 

ILLINOIS STREET INTERMODAL BRIDGE 

The Port of San Francisco proposes to construct a bridge across the Islais Creek channel one block east 
of the existing Levon Hagoop Nishkian drawbridge on Third Street. The new bridge would extend 
across the channel along the line of Illinois Street, connecting the Port's North Container Terminal at 
Pier 80, on the north side of Islais Creek, with the nurherous Port facilities on the south side of Islais 
Creek. These facilities include the Port's South Container Terminal at Piers 94-96; the adjacent 
Intermodal Container Transfer Facility, where cargo containers are transferred directly from ship to rail 
and vice versa;. Piers 90 and 92 along the south side of Islais Creek channel; and the Piers 90-94 
backlands area. 

The Illinois Street bridge would provide a more direct route for rail cargo to and from Pier 80. Rail 
traffic, destined to Pier 80 must currently travel north on a route that generally follows Interstate 280, 
more than one mile past the project site and through the Mission Bay area, beyond 16th Street, before 
returning south along Illinois Street to Pier 80. As part of the approved Mission Bay project, a portion of 
the existing rails through the Mission Bay area will be removed and are proposed for replacement with 
new rails within 16th Street, and a new switchback within a planned waterfront open space on the Terry 
Francois Boulevard right-of-way unless or until the Illinois Street Bridge is constructed. The bridge 
would reduce the existing approximately four-mile rail trip between Pier 80 and Piers 94-96, over the 
existing rail route, to a direct route of approximately 0.2 miles. When the bridge is completed, the rails 
that run near 16th Street would be removed, and there would be no need to install new rails in 16th Street 
or in the new waterfront open space. 

'The Illinois Street bridge would be approximately 28 feet wide and would have a single rail line in the 
center and two traffic lanes, one in each direction, that would overlap the rails. Thus, the bridge would 
provide a direct truck connection between the two container facilities, with trucks having access to the 
bridge only when no trains were crossing. Bicycle access would be allowed in the traffic lanes when no 
trains are crossing, but no sidewalks are proposed. 



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The Port proposes that the Illinois Street bridge be a "Lift-Segment Movable Bridge," meaning that the 
center span, which would be 60 feet long, would be constructed as three individual segments that could 
not be mechanically raised in place like a drawbridge. Instead, each of these segments could be lifted by 
a crane and stored on concrete piers that would be built next to the bridge. UnUke a dra^ybridge, a lift- 
segnient bridge is designed to be opened only infrequently, primarily for passage of maintenance vessels 
and barges. Therefore, the new bridge would probably be opened no more than once yearly. 

The proposed lift-segment bridge would have the same clearance above water as the Third Street 
drawbridge over Islais Creek, which is a minimum of 4 feet of clearance at mean higher high water level. ■ 
This would permit navigation beneath the Illinois Street bridge by small pleasure craft such as canoes, 
kayaks, and other small vessels hke rowboats. The Port believes the navigational needs of the west end 
of Islais Creek are and will continue to be for small vessels. A hand-launch dock has been constructed 
on the south shore of Islais Creek, just west of the existing Third Street drawbridge. A sand ramp has 
also recently been constructed to facilitate the hand-launching of small vessels. The Port does not 
propose to open the new Illinois Street bridge to permit the passage of larger pleasure craft or sailboats. 

The design and construction of the Illinois Street bridge would be subject to approval of a bridge permit 
by the U.S. Coast Guard, which must determine the future navigational needs of Islais Creek before it ' 
issues a permit. The Coast Guard would determine whether a lift-segment span is appropriate. The 
bridge would also require approval by the Bay Conservation and Development Commission (BCDC) 
because it would be constructed over the Bay and within the 100-foot band along the San Francisco Bay 
shoreline over which BCDC has jurisdiction. The BCDC would also be required to find the bridge 
consistent with the federal Coastal Zone Management Act. Approval could also be required from the 
U.S. Army Corps of Engineers under Section 404 of the federal Clean Water Act (including consultation 
with the U.S. Fish and Wildlife Service) and Section 10 of the federal Rivers and Harbors Act. In 
addition, the bridge would require water quality certification from the Regional Water Quality Control 
Board, under Section 401 of the Clean Water Act. Because of the federal action and funding, 
environmental review of the bridge must also include completion of a document prepared pursuant to the 
National Environmental Policy Act. In addition, the California PubUc Utilities Cominission would have 
to approve the change in rail route and abandonment of track within the Mission Bay project area. 
Funding authorization would be required from the San Francisco Board of Supervisors and the Port 
Commission must also approve the bridge project. A building permit would also be required. 

FUTURE PORT DEVELOPMENT 

The project analyzed in this SEIR also includes growth in cargo shipping at Piers 80 and 94-96 - the 
Port's two container terminals - and expansion of the Port's dredge material handling program, as well 
as potential future development of several other Port sites, or "opportunity areas," in the "backlands" 
(upshore from) Piers 90-94, and at and near Pier 70. Although the Port has not identified specific 
development proposals for these opportunity areas at this time, the Port's Waterfront Land. Use Plan does 
allow future development proposals, and these potential future uses are therefore part of the "project" as 



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defined for CEQA purposes, anticipated for the most part to be implemented by the SEIR horizon year of 
2015. The actual range of potential development is broad, with widely varying environmental impacts. 
For analytical purposes, this SEIR assumes relatively intensive uses to produce a conservative 
assessment of environmental impacts. Any actual development program or project(s) for the below areas 
(other than cargo shipping at Piers 80 and 94-96 and Port dredge material handling at Pier 94) proposed 
in the future may be reviewed by a conmiunity advisory group process set forth in the Waterfront Plan, 
and would be subject to additional project-specific environmental review. 

Cargo Shipping. The Port's two container terminals, at Pier 80 and Pier 94-96,. would potentially 
accommodate increased cargo shipping activity consisting of handling of both containerized and non- 
containerized cargo. The project therefore would include movement of a.pproximately 200,000 TEU^ of 
new cargo (beyond existing volumes of approximately 50,000 TEIJ) in addition to the cargo activity 
associated with the Industry Group leases. Of the 200,000 new TEU, 30,000 TEU is assumed to be 
accommodated by 2001, another 20,000 TEU by 2003, and 150,000 additional TEU by 2015. Cargoes 
may be containerized or bulk, depending on demand from shippers. 

Dredge Material Handling Site. The Port has recently begun storing material dredged from the Bay 
during routine maintenance dredging from Piers 35, 80, and 96. (The Port also uses storage sites in the 
East Bay.) Currently, dredge material is placed by crane onto the pier deck within a temporary three- 
acre enclosure at Pier 96 and allowed to drain and partially dry. (to about 20 percent moisture content) 
before being hauled by truck to landfills, where it is used as daily cover for solid waste landfilling 
operations. The (drained) decant water is discharged to the Bay. The Port plans to expand this operation 
and move it to Pier 94, where it would occupy up to about five acres of unpaved land north of the paved 
pier apron. At the new site, about 20,000 cubic yards of dredge hiaterial per year would be pumped from 
a barge into the drying area. It is anticipated that the off-hauling by truck of partially dried dredge 
materials would occur over a period of about two weeks during the year. Trucks would travel on 
Amador Street. 

Piers 90-94 Baeklands. This approximately 50-acre area would potentially be developed with a mix of 
about 650,000 square feet of light industrial uses and approximately 1 million square feet of commercial 
office and/or research and development uses. Office and/or research and development uses would be 
anticipated to occur in two- to three-story buildings that would be expected to include landscaped open 
spaces as part of ah overall site plan. 

Pier 70. The project analyzed in this SEIR includes development of approximately 200,000 square feet 
of new Maritime Industrial uses and an additional 200,000 square feet of General Industrial uses within 
the 55-acre Pier 70 Maritime Reserve Area. The Waterfront Plan includes Maritime Industry among the 
uses related to waterbome commerce and navigation. Maritime Industry could also include Maritime 
Support uses such as equipment storage and warehousing uses. The Plan defines General Industry as 
"facilities for enclosed and open air industrial activities, including but not limited to: recycling 

^ See footnote 7, p. 3, for an explanation of TEU (twenty-foot equivalent unit). 



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operations, automobile repair and related services, bio-remediation, sand and gravel operations, 
transmission facilities, and manufacturing operations." . . 

Pier 70 Mixed-Use Opportunity Area. The project analyzed in this SEIR includes development of this 
16-acre area, between 18th and 21st Streets and extending one to three blocks east of Illinois Street. It is 
anticipated that uses in this area would include a mix of uses, including approximately 610,000 square 
feet of conmiercial office and/or research and development space; 100,000 square feet of retail and other 
conmiercial space; and 240,000 square feet of public access and recreational maritime uses. The Port 
plans to issue a Request for Proposals to potential developers of the Pier 70 Mixed-Use Opportunity Area 
in late 2000. (An alternative considered in this SEIR would include housing on a portion of the Pier 70 
Mixed-Use Opportunity Area.) 

Western Pacific Property. This site, a former rail yard east of Illinois Street between 25th and Cesar 
Chavez (Army) Streets, will be partially occupied by a Muni Metro maintenance and storage facility that 
will be constructed as part of the soon-to-be undertaken Third Street Light Rail Extension project. The 
Muni Metro facility was analyzed in the EIR/EIS for the Light Rail Project, and will occupy about three- 
fourths of the approximately 25 -acre Western Pacific Property. No specific development projects are 
forecast for the remainder of the Western Pacific Property. However, as part of the project analyzed in 
this SEIR it is assumed that part of the remainder of this site would be occupied by General Industrial 
uses, potentially including construction-related uses such as materials storage, on an interim basis. 

B. MAIN ENVIRONMENTAL EFFECTS 
LAND USE (p. 25) 

In Phase I, six private entities would lease sites or facilities in the project area. All but one of these 
operations would be related to the construction industry, and that one entity proposes to lease a site for 
bus storage, maintenance and repair. These facilities are interim uses assumed to have leases with the 
Port at least to 2015. Most of the proposed lessees are currently located at existing sites at other 
locations in San Francisco, and would relocate to the project area. The relocation and location of the 
Industry Group operations would be a continuation, rehabilitation or expansion of industrial uses in the 
Southern Waterfront. Therefore, the Industry Group component of the project would not disrupt or 
divide the physical arrangement or impact existing character of other industrial uses in the project area or 
nearby residential communities. The majority of the Industry Group components would include a 
maritime component in their operations, and therefore would be considered maritime tenants of the Port. 

In Phase II of the project, Pier 80 and Piers 94-96 would support increased future maritime activity for 
both containerized and non-containerized cargo, consistent with the Waterfront Land Use Plan. Some of 
the additional cargo shipping would be associated with cargo activity proposed by Industry Group 
members, while other activity would be general cargo shipping. These uses would not disrupt or divide 
the physical arrangement of the adjacent Port uses or nearby residential and commercial communities, as 



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they would, represent a continuation of existing Port activity. The Port uses would therefore have a less- 
than-significant land use impact. 

With regard to non-cargo activity on Port lands, these uses would also be a continuation and expansion 
of existing maritime and industrial operations on Port property in the Southern Waterfront. These uses 
would not disrupt or divide the physical arrangement of project area uses or nearby residential - 
communities, as development would occur entirely on Port property near similar maritime and industrial 
uses, and therefore the impact would be less than significant. New uses, such as office, research and 
development, and retail uses, would not conflict with nearby maritimerrelated and industrial uses. Mixed 
use development on the Pier. 70 backlands would not disrupt or divide the physical arrangement of the 
project area uses or nearby residential communities and, although these uses would change the existing 
character in this section of the Southern Waterfront area, the impact would be less than significant 
impact because neither adjacent Port uses nor surrounding residential communities would be adversely 
affected. Rather, the mixed-use area would serve as a buffer between maritime and industrial uses 
nearest the water and residential uses in the Bay view Hunters Point neighborhood, on Potrero Hill, and in 
Dogpatch. 

The Industry Group project components address several Waterfront Plan objectives for the Southern . • 
Waterfront subarea. The Industry Group project components would help maximize the utilization of 
existing cargo terminal facilities and would also maximize the productivity of Port assets through interim 
use of property reserved for maritime expansion. Most of the Industry Group components would include 
a maritime compotient in their operations, either import or use of construction -related aggregate 
materials, or both. Therefore, the Industry Group components would not interfere with the port priority 
area designations of their sites in the Bay Area Seaport Plan! In light of the above, the Industry Group 
coniponents of the project would not obviously or substantially conflict with applicable plans and 
policies. • 

The proposed Illinois Street Intermodal Bridge would not substantially or obviously conflict with 
applicable objectives of the San Francisco General Plan or the Waterfront Land Use Plan objectives for 
the Southern Waterfront. The bridge would help maximize the utilization of existing cargo terminal 
facilities at Piers 80 and 94-96 by creating more direct and efficient rail and truck access to the Port 
container facilities on the north and south sides of Islais Greek. The bridge would be an acceptable 
maritime use as it supports marine cargo and handling facilities. No substantial conflicts with BCDC 
policies or other regulatory requirements have been identified that would prevent a finding of 
consistency under the Coastal Zone Management Act or other regulatory approvals. . 

Development of currently unprogrammed Port lands would not substantially conflict with adopted plans 
and policies. Maritime related development on Piers 70, 80 and 94-96 would help maximize the 
utilization of «x:isting cargo terminal facilities. Mixed use commercial, office and retail development on 
Pier 70 and Pier 94 backlands would promote non-maritime land uses that could be beneficial to the Port 
and compatible with maritime activities in areas .which are surplus to long-term maritime needs, although 



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introduction of office or research and development uses outside the Cargo Way, Western Pacific, or 
Pier 70 Opportunity Areas would require amendment of the Waterfront Plan to permit such uses. 
Development of the Mixed Use Opportunity Area at Pier 70 east ,of Illinois Street would promote non- 
maritime activities around the historic Union Iron Works buildings, and facilitate the revitalization of an 
area that survives as an example of San Francisco's earliest maritime industry. 

The creation of new public access, recreational maritime uses, and laridscapied open space in the mixed 
use opportunity areas would be consistent with the Southern Waterfront objectives to improve areas 
which will provide opportunities for passive and active recreational uses, and would enhance the public's 
appreciation of the waterfront by providing greater opportunities for access in a manner whicti does not 
compromise the efficiency of maritime operations. The most recent update of the Bay Area Seaport Plan 
removed the Western Pacific site from port priority area designation and most of the Pier 90-94 
backlands has also been removed from port priority area status. Therefore, anticipated future Port 
development would not interfere with the port priority area designations of their sites in the Bay Area 
Seaport Plan. 

TRANSPORTATION (p. 46) 

Travel Demand. Most of the traffic generated by Phase I of the project (primarily the Industry Group 
components) would be truck traffic in connection with the production of construction aggregates and 
shipping activity at the Port. The Industry Group project components would generate about 
2,200 vehicle trips (a trip is one way; two trips make up a round trip) per day, of which about 1,850 
would be truck trips. In the morning (a.m.) peak hour, the Industry Group components would generate 
about 480 vehicle trips, while they would'generate about 325 vehicle trips in the afternoon (p.m.) peak 
hour. An estimated 210 additional daily vehicle trips, including about 180 truck trips, would be made to 
and from the project area by the time the Industry Group components are operational, including about 
50 a.m. peak-hour vehicle trips and about 20 p.m. peak-hour vehicle trips. These trips would be 
generated by other anticipated uses on Port land, including additional cargo shipping at Pier 96 beyond 
that currently existing and future industrial activity on the Western Pacific site. By 2003, when the 
Illinois Street bridge would be in place and the Muni Third Street Hght rail line would begin service, 
nearly 1,700 additional vehicle trips, including almost 1,300 truck trips, would be made to and from the 
project area each day on Port land, including about 125 a.m. peak-hour vehicle trips and about 110 p.m. 
peak-hour vehicle trips. 

By 2015, overall daily vehicle trip generation would nearly quintuple, largely as a result of future 
development that would occur on port property, including more than 1.6 million square feet of office and 
research and development space at the Pier 70 Mixed-Use Opportunity Area and the Pier 90-94 
backlands, and 100,000 square feet of retail space at the Pier 70 Mixed-Use Opportunity Area. Also 
included is more than 1 million square feet of light, general, and maritime industrial uses at Pier 70 and 
Piers 90-94. This future port development would generate more than 14,000 daily vehicle trips, nearly 
1,800 vehicle trips in the a.m. peak hour and more than 1,700 vehicle trips in the p.m. peak hour. In 



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addition, anticipated growth in cargo shipping would increase daily vehicle trip generation from Port 
activity by nearly 50 percent (to approximately 2,450) and p.m. peak-hour vehicle trip generation by 
55 percent (to about 170), compared to 2003 levels; a.m. peak-hoiir trip generation would more than 
double, compared to 2003^ to approximately 265 vehicle trips. Industry Group truck traffic would also 
increase because, while the percentage of raw materials brought in by ship would increase, the increased 
production volume assumed by 2015 would result in more local truck trips by cement mixers and asphalt 
trucks making deliveries. 

Traffic Traffic generated; in the near ternii mostly by the Industry Group components, would adversely 
affect two intersections: morning (a.m.) peak-hour operations at the signalized intersection of Third 
Street and Cargo Way would deteriorate from Level of Service (LOS) B under existing conditions to 
LOS F, and at the signalized intersection of 25th and Third Streets, afternoon (p.m.) peak-hour 
conditions would deteriorate, also to LOS F from an existing LOS B. These changes would occur in the 
near term, by about 2001, By 2003, with additional traffic from development on Port land and from 
background growth, p.m. peak-hour conditions at Third and Cargo would also deteriorate to LOS F 
without the Illinois Street Bridge, from LOS C at present and LOS D with Existing-plus-Industry Group 
(near term) conditions. Also by 2003, a third intersection would be adversely affected: the unsignalized 
intersection of Amador Street and Cargo Way would deteriorate to LOS F in the p.m. peak hour with 
Phase I traffic and completion of the Illinois Street bridge. However, conditions at Third and Cargo 
would improve with completion of the bridge and the resulting redistribution of truck traffic, so that this 
intersection would operate at LOS C in the a.m. peak hour and LQS D in the p.m. peak hour. With the 
bridge, conditions at this intersection would remain acceptable through 2015. Conditions in the p.m. 
peak hour at 25th and Third would improve to LOS C following implementation of the Third Street Light 
Rail Project, which will add a separate left-tum signal phase at that intersection. The impact at Amador 
and Cargo could be mitigated through installation of a traffic signal; with a signal, conditions would 
remain acceptable through 2015. 

At the unsignalized intersection of Mariposa Street and the Interstate 280 southbound on- ramp, 

which currently operates at LOS F during both peak hours. Phase I of the project would result in 
increased delays during both the a.m. and p.m. peak hours. By 2015, this intersection is scheduled to be 
signalized, and the signalized intersection would operate at an acceptable LOS under 2015 No-Project 
conditions (i.e., without the Industry Group project components or future Port development^^ However, 
the addition of Phase I and Phase II project traffic by 2015 would result in unacceptable conditions at this 
intersection, even signalized: LOS F in the a.m. peak hour and LOS E in the p.m. peak-hour. This 
would be a significant effect, and would not be mitigable, as the intersection capacity would be 
exceeded. The other 11 study intersections would operate at acceptable levels of service (LOS D or 
better) in all scenarios prior to 2015. 



Mitigation for intersection levels of service identified in the Mission Bay Subsequent EIR (Case No. 96.77 IE; Final SEIR 
certified September 17, 1998) is keyed to generation of specific volumes of traffic, and thus, based on development 
assumptions, is assumed to be in place by 2015 at the Mariposa Street / 1-280 southbound on-ramp intersection, although it 
could occur earlier. 



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The Illinois Street bridge would allow for removal of railroad tracks that currently run through the 
Mission Bay project area and would represent a benefit to traffic patterns in the Mission Bay area: the 
approved Mission Bay plan currently calls for the tracks that connect the Union Pacific main line to 
those on Illinois Street to be replaced with tracks in the 16th Street right-of-way. With completion of the 
Illinois Street bridge, there would be no need for tracks in 16th Street, thereby eliminating a potential ' 
conflict between trains and vehicle traffic. 

By 2015, all intersections except Third and Cesar Chavez. Streets would operate at acceptable levels of 
service under No Project conditions, accounting for background growth including traffic from the 
Hunters Point Shipyard redevelopment project, the Mission Bay project, and the Bayview-Hunters Point 
redevelopment area. The poor LOS at Third / Cesar Chayez Streets would result from changes in lane 
configuration due to the Third Street Light Rail Project and increased background (non-project) traffic. 
Additional traffic from future Port development (Phase II of the project), along with Phase I traffic, 
would result in unacceptable conditions (LOS E or LOS F) at eight of 17 study intersections in the a.m. 
peak hour and at 10 of 17 study intersections in the p.m. peak hour. Therefore, the project would result 
in a significant effect at each of these intersections. Mitigation has been identified to reduce impacts to a 
less-than-significant level at Third / 25th Streets; Illinois / 25th Streets; Pennsylvania Street / 1-280 
southbound on-ramp; Pennsylvania / Cesar Chavez Streets; and Illinois Cesar Chavez Streets, as well as 
at Amador Street / Cargo Way, as described above (see Chapter IV, Mitigation Measures, p. 144). 
Impacts at five intersections would not be mitigable. These include Mariposa Street / 1-280 southbound 
on-ramp, described above; Mariposa Street / 1-280 northbound off-ramp; Third / Mariposa Streets; Evans 
Avenue / Cesar Chavez Street; and Third / Cesar Chavez Streets.'* 

Transit. Approximately 9 percent of employee trips to work for Phase l of the project (primarily the 
Industry Group components) are anticipated to be made using transit, which is half the percentage 
typically assumed for southeastern San Francisco. This is because transit access to the Industry Group 
sites is currently limited, and many workers would be expected to begin and end their work days prior to 
more typical work hours. As a result. Phase I would generate fewer than 25 transit trips in the a.m. and 
p.m. peak hours. These new transit riders would represent a very small increase over existing ridership 
in the area, and would not result in a significant effect. 

Phase II of the project includes additional growth in cargo shipping and related activities at Pier 70 (the 
maritime reserve area). Pier 80, and Piers 94-96, as well as development of non-maritime and non- 
industrial uses at the Pier.70 Mixed-Use Opportunity Area and the Piers 90-94 backlands. The Mixed- 
Use Opportunity Area and the backlands together would include 1.6 million square feet of office and/or 
research and development space and 100,000 square feet of retail space, which would have trip 
generation characteristics such that transit use among commuters and visitors would likely be greater 
than that assumed for the maritime and industrial uses elsewhere in the project area. Of the estimated 



The Department of Parking and Traffic is consideririg the addition of a second northbound left-turn lane at the Third / C^sar 
Chavez Streets intersection. However, this would require the acquisition of additional right-of-way on Third Street at the 
southeast comer of the intersection, where there is an existing building. The feasibility of this measure is not known. 



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approximately 680 a.m. peak-hour and 625 p.m. peak-hour transit trips, about 80 percent would be made 
in the peak direction (to the work place in the morning and from the work place in the afternoon). 

The increase in transit ridership by 2015, along with growth in ridership due to other development in the 
project area and elsewhere, could be accommodated by Muni routes serving the project area. On the 
Third Street Light Rail line, the percent of p.m. peak-hour, peak-direction transit vehicle capacity used 
("capacity utilization") would be 83 percent in the p.m. peak hour. The project would add about 450 new 
riders, and increasing capacity utilization from 45 percent (with cumulative growth but without the 
project) to 83 percent with the project. Because adequate capacity would rerriain, the effect would not be 
significant. Peak-direction capacity utilization on the three principal bus lines that serve the project area 
(19-Polk, 22-Fillmore, and 48-24th Street/Quintara Avenue) would be between 90 percent and 
100 percent. Only the 22-Fillmore would operate at capacity; however, project ridership would amount 
to only 6 trips, and would not result in a significant effect. Project ridership on the other lines would be 
40 trips or less; adequate capacity would remain on these lines and the project impact would not be 
significant. 

Project ridership by 2015 on regional transit carriers would total about 190 p.m. peak-hour trips, mostly 
on BART and Caltrain. Both BART (to the East Bay) and AC Transit would operate in excess of 
capacity, although BART trains would remain within the system's standard of 1 15 percent for the three- 
hour peak period. Project-generated ridership would increase BART capacity utilization by less than 
0.5 percent, and AC Transit capacity utilization by less than 0.3 percent, and therefore would not result in 
a significant impact, because the contribution to cumulative overcrowding would be negligible. 

Parking. Parking effects of Phase I development would be limited, because parking demand generated 
by the Industry Group components would be limited almost entirely to employee vehicles, and each of 
the Industry Group sponsors has indicated plans to provide for on-site employee parking. Future Port 
development in Phase II of the project would include more conventional land uses. The development of 
more than 1.6 million square feet of office and research and development space at the Pier 70 Mixed-Use 
Opportunity Area and the Pier 90-94 backlands would result in an estimated demand for nearly 
3,300 parking spaces, or about two-thirds of the parking demand for Phase II of the project. Actual 
parking demand and requirements could vary by use and by site, depending on the actual uses that are 
proposed in the future on Port property. It is assumed that the relative lack of site Constraints (i.e., the 
availability of large development sites) would facilitate the provision of both adequate parking and off- 
street loading space for individual projects, meaning that no significant effects would be expected. It is 
also assumed that large projects that may be proposed would be subject to detailed transportation 
analyses. 

Bicycles and Pedestrians. Phase I project components (primarily those of the Industry Group) would 
generate little in the way of pedestrian or bicycle traffic, so the potential effects of the project would be 
largely those of increased truck traffic on existing pedestrians and bicycles, mainly bicycles on Third 
Street, where increased traffic from the project and other sources could increase the potential for 



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conflicts. The Department of Parking and Traffic is also considering a new bicycle route on Illinois 
Street. Pedestrian activity would be accommodated on existing sidewalks. It should be noted that much 
of the project area east of Illinois Street is, and will continue to be, a heavy industrial area, and that the 
provision of pedestrian access for casual walkers is not necessarily the public benefit it would be in areas 
of the waterfront north of Pier 70. 

By 2015", with implementation of Phase II of the project (future Port development, including increased 
cargo shipping), traffic volumes would increase further, and pedestrian and bicycle use in the project 
area would also be anticipated to increase, particularly if mixed-use development occurs as planned at 
Pier 70 and at the Pier 90-94 backlands. Development of these mixed-use projects would be reviewed by 
the Port to ensure that adequate pedestrian access is provided, potentially including construction of 
sidewalks where none exist on the perimeter of the development sites, and would also be required to 
include bicycle parking in accordance with the requirements in the Planning Code. Thus, pedestrian and 
bicycle conditions would be improved from conditions at present. 

The project would not adversely affect pedestrian access to the Bay Trail, which is designated on Illinois 
Street north of 24th Street and on Third Street south of 24th Street. Existing sidewalks on these streets 
would remain in place and would continue to function as part of the Bay Trail. 

Construction. Construction activity could occur simultaneously at several of the Industry Group project 
sites, beginning in early 2OOI. However, as interim facilities without permanent structures, mostly 
developed on already paved land, these components would not generate substantial or lengthy 
construction impacts. Effects on local traffic would be considerably less extensive than those described 
for the Phase I project itself, because the volume of construction-related traffic would be jnuch less than 
the traffic volumes once all Industry Group components were operational. Phase II, including future Port 
development of the Pier 70 Mixed-Use Opportunity Area and the Piers 90-94 Backlands, could result in 
temporary construction-period impacts much like those of typical urban development, but would not be 
considered significant. 

AIR QUALITY (p. 78) 

Construction-period impacts were evaluated qualitatively and with reference to the dust control measures 
that can be implemented to reduce the temporary air quality effects associated with construction. 
Operational impacts were evaluated quantitatively through estimates of pollutant emissions and 
concentrations. Operational impacts were examined for two years: 2003, when the Industry Group 
project components would be in operation, the Illinois Street intermodal bridge would be in place, and 
the Muni Third Street light rail line is anticipated to begin operations; and 2015, by which time the 
Future Port Development described in the Project Description would occur. With implementation of the 
Industry Group components, there is anticipated to be a shift, over time, in the transport of aggregate raw 
materials used in the production of ready-mix concfete, from truck to ship. These shifts in mode of 
transport are reflected in this analysis, as they are in the transportation analysis.. 



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Two separate operational analyses were conducted for both analysis years. One aspect of the analysis 
quantifies the net change in emissions due to project-related sources from a regional perspective 
(emissions occurring within the multi-county air basin), including emissions from stationary sources 
(e.g., industrial plants and the like) and from mobile sources (i.e., motor vehicles, ships, trains, etc.). 
New emissions are calculated regardless of where, they occur in the Bay Area. The other aspect of the • 
analysis identifies what portion of the regional emissions would be experienced locally. The SEIR , 
quantifies local project emissions and effects, in particular, due to project-related stationary sources and 
related truck traffic, on the Bay view-Hunters Point neighborhood. These calculations are provided in 
recognition of the Qoncentration of industrial uses proposed, and the anticipated corresponding 
concentration of truck traffic, and because a substantial volume of the Phase I vehicle trips related to the 
Industry Group project components are currently being made, under existing conditions, to. and from 
other parts of San Francisco. Therefore, the change in location of, for example, existing concrete plants, 
would result in very little change in emissions viewed from a regional perspective, although there would 
be the potential for a proportionately larger increase in the concentrations of certain key emissions in the 
immediate vicinity of the new plants (with a corresponding decrease in emissions concentrations at the 
existing locations). These localized calculations report results for carbon monoxide concentrations at 
local intersections, as well as concentrations of respirable particulate matter (PM-10) and diesel 
particulate matter. 

Construction Impacts. Grading and other ground-disturbing construction activities would temporarily 
affect local air quality intermittently during construction activities for each project component, causing a 
temporary increase in particulate dust and other pollutants. Heavy equipment would generate fugitive 
dust and would emit combustion products, including ozone precUrsprs (ROG and NOx), carbon 
monoxide, sulfur dioxide, and PM-10, but the mOst significant emissions would be fugitive dust. 
BAAQMD has identified a set of feasible PM-10 control measures for construction activities, and 
mitigation was included in the Waterfront Plan EIR to reduce construction-related air quality impacts to a 
less-than-significaht level; a revised version of this mitigation measure is included in this SEIR (see 
p. 146). With implementation of this measure, construction-related air quality effects would be reduced 
to a less-than-significant level. 

Operational Impacts - Regional. Maximum daily emissions of reactive organic gases (ROG), nitrogen 
dioxide (NO^), and respirable particulates (PM-10) from all project components combined would exceed 
the significance threshold of 80 pounds per day in both 2003 and 2015. The significance threshold for 
annual emissions of 15 tons per year would also be exceeded for ROG and NOx each year. Therefore, 
the project would result in. a significant effect with regard to emissions of criteria pollutants. This 
significant impact would occur regionally within the multi-county air basin and are not directly reflective 
of local conditions. This impact cannot be reduced to a less-than-significant level because of the 
magnitude of the project. The source of the greatest amount of emissions would be ship and rail traffic. 

Emissions of all three pollutants generated by trucks from the Industry Group components in 2003 would 
decrease, compared to existing conditions, because of the shift in means of transport from trucks to ships 



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and rail for much of the raw material used in the production of ready-mix concrete. By 2015, emissions 
would increase based on the increase in concrete and asphalt production and the corresponding increase 
in truck traffic, as well as the increase in cargo shipping at the Port. Some of the increase in vehicle 
emissions would be offset by improved emissions control technology that would be implemented over 
time. 

Operational Impacts - Local. Project-related traffic could result in localized "hot spots" or areas with 
high concentrations of carbon monoxide concentrations around stagnation points such as major 
intersections and heavily traveled and congested highways and roadways. To evaluate "hot spot" 
potential, a microscale impact analysis was conducted adjacent to four representative intersections. within 
the project area where the project would result in relatively higher volumes of traffic: Third Street / 
Cesar Chavez Street, Third Street / Mariposa Street, Illinois Street / Cesar Chavez Street, and Third 
Street / Evans Avenue. -It was assumed that if the relatively higher volumes of project-generated traffic 
at these intersections did not result in adverse impacts, impacts at other nearby intersections would 
experience similar or less substantial effects. No exceedances of the state one-hour or eight-hour 
standard were identified, and the impact relative to localized carbon monoxide would be less than 
significant. 

To examine the potential health effects of localized emissions of particulate matter, including PM-10 and 
diesel particulate, dispersion modeling was conducted to determine whether the local concentration of 
such particulates would be markedly increased in the Bay view-Hunters Point neighborhood as a result of 
emissions due to the project. Particulates were selected for dispersion modeling because of their 
potential adverse effects on respiratory health. The sensitive receptors selected include several schools 
and parks nearest the project area, in Bay view/Hunters Point and on Potrero Hill. These sites were 
chosen because children tend to be more susceptible than healthy adults to certain effects of air pollution. 
Also, the school sites are representative of the exposure locations of the surrounding residential 
neighborhood. 

Each of the Industry Group project components, which would represent "stationary sources" of 
particulate emissions, is proposed to include "best available control technology" (BACT) to control 
emissions, consistent with current regulations. For aggregate-handling operations (Bode Gravel, Mission 
Valley Rock, RMC Pacific, British Pacific Aggregates), this includes maintaining a moisture content in 
the aggregate that is high enough to eliminate PM-10 "fugitive" emissions (wind-blown dust that could 
otherwise escape into the surrounding air). A water spray system would be installed at each aggregate- 
handling facility, including Bode Gravel, Mission Valley Rock, RMC Pacific, and British Pacific 
Aggregates. Fine aggregate material (sand) would be maintained with a moisture content of 
approximately 5 percent, because such material with a moisture content of 4.5 percent or more produces 
virtually no fugitive emissions. Coarse aggregate (gravel) would be kept damp on the surface, .which 
would also virtually eliminate fugitive dust. Aggregate would be stored in bunkers at ready-mix and 
asphalt plants, rather than open piles, with water spray (including the use of surfactants, as necessary, to . 
bind the water and dust to the aggregate) applied to maintain adequate moisture content to control 
emissions at both production and shipping/storage operations. ISG Resources, which would handle 



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powdery fly ash, would install BACT dust collection equipment to accommodate truck and rail transport 
and would use pneumatic equipment for transfer of fly aslv. 

The asphalt plant proposed by Mission Valley Rock (and by British Pacific) would include controls on 
the drum mixer where the asphalt cement and aggregate are mixed. Drum mixer(s) would be fired \yith 
natural gas, consistent with BACT recommendations, and particulate emissions from the aggregate 
drying and mixing process would be controlled with a fabric filter, also consistent with BACT. Such 
filters can achieve control efficiency of greater than 99 percent. Emissions of toxic substances from the 
asphalt plant would include mostly benzene and formaldehyde which would volatilize when the asphalt 
cement is heated. Most of these eihissions would occur at the drum mixer/dryer. Using emission factors 
recently reported by U.S. EPA for hot mix asphalt plants (U.S. Environmerital Protection Agency, 20G0) 
in the dispersion modeling analysis, the maximum carcinogenic risk at sensitive receptors was estimated 
to be 0.3 in a million. 

The PM-10 modeling for the years 2003 and 2015 revealed that the maximum incremental contribution 
to 24-hour PM-10 concentrations at any given receptor would be 1.2 micrograms per cubic meter in 2003 
and 1.6 micrograms per cubic meter in 2015. In both cases, these maximurhs would be well below the 
significance standard of 5.0 micrograms per cubic meter, and would be registered at Youngblood 
Coleman Playground, on Hudson Avenue at Mendefl Street, which is the closest sensitive receptor 
downwind from the concentration of proposed Industry Group components along Islais Creek. This 
playground is located adjacent to the residential area on the hill overlooking Hunters Point shipyard. The 
PM-10 concentrations at all other receptors modeled would be lower than these values. 

Based on meteorological conditions, the maximum 24-hour concentration at Youngblood Coleman 
Playground would occur on fewer than 25 days per year. Winds in the area are usually from the 
southwest through northwest, occurring about 65 percent of the time. For the westerly, wind directions, 
pollutant emissions from the project would be transported out over the Bay. 

Modeling was also conducted to determine the maximum annual average PM-10 concentrations, in 
addition to maximum daily concentrations. The maximum annual concentration in 2003 would be 
0.09 micrograms per cubic meter, while in 2015, the maximum concentration would be 0.12 micrograms 
per cubic meter. As with the 24-h6ur concentrations, these highest annual averages would be well below 
the significance standard of 1.0 microgram per cubic meter, and would also be at Youngblood Coleman 
Playground. 

To determine the potential implications of increased emissions of diesel particulates, a newly designated 
toxic air contaminant, the relative risk of long-term exposure was calculated and compared to the 
BAAQMD's standard of 10 in 1 million (10 additional cancer cases per million persons beyond the pre- 
existing risk), based on the BAAQMD permitting procedure for stationary sources. In 2003, the 
maximum incremental risk of cancer from diesel particulate emissions resulting from the project is 
estimated to be 7.5 in 1 million (7.5 additiofial cancer cases per million persons, beyond the risk from 
other sources), based on 24-hours per day exposure over a period of 70 years. In 2015, the project's 



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cancer risk from diesel particulate would be 9.0 in 1 million. Both results are below the 10 in 1 million 
standard and therefore are not considered significant. To put the 10 in 1 million standard in perspective, 
the B AAQMD estimates that the incremental cancer risk from exposure to current ambient levels of 
toxic air contaminants - excluding diesel particulate matter - is 199 in a million, and the California Air 
Resources Board estimates the statewide cancer risk due to essentially all toxic air contaminants at 
758 in 1 million, of which 540 in 1 million, or about 70 percent, is estimated to be due to diesel 
particulate. 

As noted in the Setting, the analyses in this report do not assume implementation of any of the proposed 
rules or regulations regarding diesel emissions. Implementation of some or all of these proposals would 
reduce the cancer risk from diesel particulate to less than described here. 

Odorous Emissions. The B AAQMD CEQA Guidelines provides buffer distances that can be used to 
identify areas where significant impacts from proposed odor sources, such as an asphalt batch plant, 
could occur. Generally, odor impacts at sensitive receptor locations beyond the identified buffer 
distances can be presumed to be less than significant without further analysis. For sensitive receptor 
locations located within the buffer distances, a more detailed odor impact analysis is generally 
warranted. For an asphalt batch plant, the B AAQMD-reeommended buffer distance is 1 mile. 

The asphalt plant that could be constructed and operated between the Port and Mission Valley Rock 
would be a potential source of odors and odor complaints. Emissions of volatile organic substances, 
including toxic and odorous substances, can occur from heated asphalt cement that is used in production 
of asphalt concrete. Such emissions usually emanate from the drum mixer, where the asphalt cement is 
mixed with aggregate to create asphalt concrete. Mission Valley Rock proposes to use a counter-floNV 
type druni mixer, which prevents direct contact between the material being mixed and the hot exhaust 
gases in the dryer. Consequently, the temperature of the asphalt mix would be reduced, compared to 
other mixers, and vapor emissions, some of which are odorous, would be minimized. 

Residential areas are located within one mile of the potential asphalt plant site, generally to the south and 
to the northwest. The closest residences are located approximately one-half mile south of the potential 
asphalt plant site in the residential area that is south of Fairfax Avenue in the Bay view-Hunters Point . 
neighborhood. Other, more distant, residences are located to the southwest and southeast. Odors may be 
perceived at these residences when the plant would be operating during periods when stagnant • 
atmospheric conditions (i.e., little vertical air movement and low wind speeds) would coincide with 
winds blowing in their general direction. However, the confluence of these three factors (plant 
operation, stagnant atmosphere, and worst-case winds) would be rare since the plant would not normally 
operate during nighttime hours when stagnant conditions more frequently occur; high (near-ground- 
level) atmospheric stability rarely occurs during daytime hours when the plant would normally be in 
operation; and winds blowing in the direction of these residences occur only, about 18 percent of the 
time, or approximately 65 days per year. Thus, although the buffer distance between the proposed plant 



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site and the nearest residential areas would not be ideal, the distance would be substantial, and 
operational and meteorological factors would tend to diminish the potential impact. 

The buffer between the proposed plant site and the nearest residential areas to the iiorthwesf would be 
about three-quarters of a mile. Winds in the direction of these residences occur about 9 percent of the 
time. Thus, like the. residences to the south, although the buffer distance between the proposed plant site 
and the nearest residential areas would not be ideal, operational and meteorological factors would tend to 
diminish the potential impact. ; 

In summary, the proposed asphalt plant could raise the potential for odor impacts and coiriplaints, but the 
related impact would not be significant because the plant would be designed to minimize volatile 
emissions (including odorous emissions) and because favorable operational and meteorological factors 
would serve to diminish the possibility for annoying odors when most residents are home. In addition, as 
discussed in the setting section, the BAAQMD's /?M/e5 and Regulations provide a regulatory mechanism 
to remedy odor complaints in the unlikely event that they would become frequent. . 

Cumulative Impacts. According to ih& BAAQMD CEQA Guidelines, because the project would exceed 
the regional significance criteria of 80 pounds per day and 15 tons per year for both ROG and NO^^ (and 
for PM-10 on a daily basis), it would also result in a significant cuinulative effect. It should be noted, 
however* that the project-specific significant and cumulative effects are largely a construct of the 
BAAQMD's analysis methodology, which are geared more to a single development project, rather than a 
series of project components analyzed together, as in this SEIR. This finding of significant effect with 
respect to air quality does not necessarily mean that emissions, when modeled at the local level, will 
exceed state or federal standards. V 

For carbon monoxide, the dispersion modeling results characterize cumulative conditions because a 
background concentration is inherent in the analysis and because background traffic volumes were 
included in the transportation analysis on which the carbon monoxide analysis was based. Neither 
project-specific nor cumulative carbon monoxide concentrations experienced locally would be 
significant. ; ; ' " \ - ' 

For PM-10 and diesel particulate, it is more difficult to quantify a cumulative concentration because of 
the large number of sources and their. different locations. Locally, emissions from project sources, 
including both stationary and mobile sources, would be combined with emissions from other sources, 
primarily including area traffic (local streets and freeways), as well as large stationary sources such as 
the Potrero and Hunters Point power plants. These cumulative concentrations cannot be easily 
quantified, given the array of sources in the existing environment, and are therefore considered 
significant. Local concentrations of pollutants would continue to be affected by activity levels in the 
area,''by climate conditions, and by improvements in technology and fuel formulae. 

A majof cumulative project that rnay occur in the area is a proposal to expand the electrical power output 
of Southern Energy's Potrero power plant. A modeling analysis reported in the Application for 



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Certification submitted to the California Energy Commission indicates that the maximum 24-hour' 
average PM-10 increment would be about 1.0 microgram per cubic meter. This maximum increment, 
combined with the PM-10 increment from the project, W9uld be below the signiftcance threshold of 
5.0 micrograms per cubic meter. Furthermore, if the Potrero plant expansion is approved, it is expected 
that the existing Hunters Point power plant, on Evans Avenue at Hunters Point Expressway, would be 
closed, under an agreement between PG&E, the operator of the Hunters Point plant, and the City. 
Closure of the Hunters Point power plant would result in a decrease in emissions of both criteria 
pollutants and toxic air contaminants in the immediate vicinity of the residential area overlooking 
Hunters Point Shipyard. 

Cumulative air quality effects are typically discussed in terms of a project's consistency with the most 
recent Clean Air Plan (i.e., the '97 Clean Air Plan). Consistency with the plan is evaluated with 
reference to the population and employment assumptions used for the plan and with reference to 
Transportation Control Measures (TCMs). (The project would have little growth-inducing effect, and 
thus, the project would be consistent with the population and employment assumptions in the plan.) The 
'97 Clean Air P/an identifies a list of Transportation Control Measures (TCMs) that are to be 
implemented by local governments. These TCMs include support for voluntary employer-based trip 
reduction programs; improvement of bicycle access and facilities; improvement of arterial traffic 
management; development of local clean air plans, policies, and programs; implementation of 
demonstration projects; and promotion of pedestrian travel and traffic calming measures (Bay Area Air 
Quality Management District, 1999a). The City and County of San Francisco administers programs that 
implement all of these TCMs, and, while Phase I of the project, by its. nature, does not further any of the 
TCMs in particular, none of the project components would interfere with their implementation, and thus 
the project would not be inconsistent with the '97 Clean Air Plan. TCMs could be implemented as part 
of Phase II of the project, which would include development of more typical urban land uses. 

In summary, the project would result in a cumulative significant regional impact on air quality, in that 
daily volumes of the three criteria air pollutants of most concern - reactive organic gases (ROG), ' 
nitrogen dioxide (NO^), and respirable particulates (PM-10) - would exceed Bay Area Air Quality 
Management District (and SEIR) significance thresholds, and annual emissions of ROG and NOx would 
also exceed annual thresholds. Locally, cumulative carbon monoxide concentrations would be less than 
significant. Cumulative concentrations of PM-10 and diesel particulate experienced locally, while 
unknown because of the wide array of sources in the existing environment, could exceed significance 
thresholds. Even though the project would not exceed new source criteria for PM-10 or the 10 in 
1 million risk level for particulates from diesel emissions, the project would add some increment to 
existing local PM-10 and diesel emissions. Monitoring date from the nearest monitoring stations 
indicates some exceedances of the state PM-10 standard. Therefore, to be conservative, these emissions 
are deemed cumulatively significant, although the project itself would not have a significant effect with 
regard to local concentrations of PM-10 or diesel particulate. 



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HYDROLOGY AND WATER QUALITY (p. 104) 

The proposed development in the Southern Waterfront area would result in changes in the volume of 
surface water runoff from stormwater due to changes in the extent of impervious surfaces and would 
change the volume of wastewater (sewage) and stormwater discharged to the Bay from the City's 
combined sewer system. In general, replacement of unpaved areas with structures, pavement or other 
impervious surfaces would reduce the infiltration of rainwater and would increase the volume of 
stormwater runoff flowing directly from the project site to the Bay. Development of commercial and 
industrial uses would also result in increased wastewater flows to the combined sewer system. Increases 
in volume of wastewater flows and any increases in the volume of stormwater runoff that is piped to the 
City's combined sewer system could in turn affect the volume; of treated effluent and combined s^wer 
overflows discharged to the Bay. Increases in direct discharge of stormwater runoff, treated effluent, and 
cojnbined sewer overflo\ys to the Bay could affect water quality. - 

This EIR assumes that for the Industry Group Projects neither the Port nor the tenants would construct 
on-site infrastructure related to stormwater collection, and there would be ho new connections to the 
combined sewer system to capture stormwater runoff, because the Industry Group components would be 
considered interim Uses (with kases limited in length such' that major capital investment in storm 
drainage infrastructure would not be economically feasible). Therefore site conditions with respect to 
drainage infrastructure are anticipated to remain the same as existing conditions. Site! locations currently 
draining to the Bay would continue to do so, and locations currently draining to the City's combined 
sewer system would continue as well. 

Under the Industry Group projects, the total site areas for all projects would be about 32 acres. Of this 
32 acres, about 25.5 acres is currently considered to be impervious surfaces, with pavement or structures 
built on it; the remaining 6.5 acres, consisting of most of the Mission Yalley Rock-Bode Gravel site at 
Pier 92, is unpaved. This site would be paved, resulting in an increase in runoff from the Industry Group 
sites by about 12 percent, compared to existing conditions; the overall increase from all project component 
sites would be 3 percent. The increase in direct stormwater flow to the Bay would be approximately 
1.4 million gallons per year. Any stormwater runoff from the project site would be required to comply with 
RWQCB regulations under the NPDES program. Therefore, the rriinor increase in runoff associated with the 
Industry Group sites would be considered less than significant with mitigation. 

Future Port development would generate an estimated 300,000 gallons per day of wastewater, or less 
than 0.4 percent of the current City wide total of 84 million gallons per day (and less than 0.5 percent of 
the 67 million gallons per day currently treated at the Southeast Water Pollution Control Plant). The 
project impact on dry-weather flow and the incremental impact of wastewater flow on the volume of 
combined sewer overflows would be considered less than significant. 

The approximately 100 acres where future Port development would occur is currently about one-fourth 
paved or otherwise covered with impervious surfaces. Under worst-case assumptions, the full build out 
of these projects would result in an increase of about 60 acres of impervious surfaces. This would 



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represent an estimated 35 percent increase in surface water runoff from stormwater in the area occupied 
by the future Port development sites, based on rainfall, runoff and land use assumptions developed for 
the City Public Utility Commission's Bayside Cumulative Impact Analysis in 1998. The estimated 
increase in runoff volumes would be about 12.5 million gallons per year, a 26-percent increase over 
existing runoff from all project component sites. Together with Phase I components, the increase would 
be 29 percent. 

The Waterfront Plan EIR assumed that storm drainage from up to 100 acres of Port land uses could be 
piped to the City's combined sewer system. This could result in a measurable increase in bayside flows, 
made up of treated effluent and combined sewer overflows. This runoff would contribute to a 
cumulative increase of approximately 44 million gallons per year in combined sewer Overflows at Islais 
Creek. Even though this increase would be permitted, recent EIRs have conservatively found the 
cumulative increase in combined sewer overflows to be a significant impact. Mitigation Measure D.3, 
p. 150, would reduce this impact to a less-than-significant level by directing stormwater flow to the Bay 
with appropriate treatment to meet regulatory requirements, without increasing the volume of combined 
sewer system overflows. 

Stormwater runoff from urban areas is a known source of pollutants to receiving waters. Typical sources 
of pollutants could include fluid leaks from vehicles, brake pad wear, tire abrasion, pavement wear, 
sediments, pesticides from landscaped areas, and atmospheric deposition. Both oil and grease and 
sediments can act as a carrier for other pollutants as well as representing a type of pollutant. The types 
of pollutants niay include metals, hydrocarbons, and organic pollutants as well as sediments. During 
rainstorms, these pollutants may be mobilized and transported in the stormwater runoff to receiving 
waters. Sometimes the first flush of each storm contains the highest concentration of pollutants, but 
release of pollutants to stormwater depends on rainfall patterns, intensity and site-specific conditions.. 
All industrial users that would discharge stormwater runoff either directly to the Bay by sheet flow or 
through isolated storm drain systems would be required to comply with NPDES permit regulations. 
These regulations would likely be met through the Industrial Activities Stormwater General Permit 
adopted by the State Water Resources Control Board, but could alternatively be met through an industry 
specific permit or an individual permit. 

The construction aggregate-related Industry Group project components, for which sediment in 
stormwater runoff would be a primary water quality concern, would include facilities such as settling 
ponds and sediment basins to ensure that neither stormwater as sheet flow nor process water (for 
example, water used to wash out cement mixers) is transported directly to the Bay without removal of 
sediment and other solids. Much of the process water would be reused in Industry Group operations. 

Compliance with NPDES permit conditions, including preparation and implementation of a Stonnwater 
Pollution Prevention Plan, would minimize potential water quality degradation associated with 
stormwater runoff. In addition, implementation of Mitigation Measure D.2 (implementation of source 
control Best Management Practices consistent with those identified in the Industrial / Commercial Storm 
Water Best Management Practices Handbook) and of measures identified in the Waterfront Land Use 
Plan EIR (and also presented in Section IV of this report) for tenants to participate in the Port's 



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'stormwater monitoring program would further reduce the potential for Bay water quality degradation. 
Therefore, long term water quality impacts associated with stormwater runoff from Industry Group 
project components would be considered less than significant with mitigation. 

The Port's planned location of an expanded dredge material handling facility at Pier 94 would result in 
runoff back to the Bay of decant waiter from dredge material placed at Pier 94. The Regional Water 
Quality Control Board (RWQCB) would require routine testing of the decant water to ensure that 
sediment levels are below accepted criteria, and' that the water does not contain chemicals (e.g., heavy 
metals) or other constituents at levels in excess of regulatory requirements. If contaminant levels were in 
excess of applicable requirements, the RWQCB would require that the Port treat the decant water prior to 
discharging it to the Bay. Treatment could involve removal of settled solids, activated charcoal 
treatment, and other methods. Operation of the dredge material storage facility in compliance with the 
required, discharge permit frorh the RWQCB would ensure that water quality effects on the Bay would be 
less than significant. 

The future Port development that would occur by 2015 could have similar effects to those described for 
the Industry Group project components. Potential industrial and commercial activity on currently 
unprogrammed Port lands at Pier 70 and at the 90-94 backlands would likely entail placement of large 
areas of impervious surfaces (buildings and pavement), which during dry weather accumulate pollutants 
associated primarily with'industrial or urban use. Under the potential future Port development projects, 
about 200,000 square feet of maritime industry uses are proposed for the Pier 70 Maritime Reserve. As 
discussed in the Waterfront Plan, niaritime industry uses may include waterbome commerce and 
navigation and maritime support uses such as equipment storage and warehousing uses. As with the 
Industry Group components, compliance with NPDES permit conditions by developers on 
unprogrammed Port lands would minimize potential water quality degradation associated with 
stormwater runoff. 

Program-level water quality impacts associated with maritime uses are described in detail in the 
Waterfront Land Use Plan EIR and are summarized briefly here. Any shipping or boating activity would 
involve handling and storage of chemical that could be discharged to surface waters. Potential pollutant 
sources include fuels, bilge water, boat cleaning and maintenance materials, sewage from boats and 
miscellaneous debris. Maritinie uses could also increase the potential for fuels spills to the Bay. 
However, as described in the Waterfront Plan EIR, there are numerous regulations in place to protect 
water quality impacts associated with maritime uses. These include: federal Oil Pollution Act and 
California Oil Spill Response Act, RWQCB and U.S. Coast Guard permits for discharges from ships or 
boats, and NPDES permits for runoff from ship and boat repair facilities. Compliance with these 
regulations would minimize the potential for water quality degradation associated with maritime uses. 
Therefore, long term water quality impacts associated with maritime uses would be considered less than 
significant vyith mitigation. 



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Construction of the various project components could affect water quality due to grading and 
earthmoving activities, use of fuels and other chemicals for construction equipment, and demolition and 
construction in proximity to the Bay. Grading and earthmoving activities would result in exposure of 
soil during construction and could result in erosion and excess sediments carried in stormwater runoff to 
surface waters. In addition, construction activities would also likely require temporary on-site use and 
storage of vehicles, fuels, wastes and other pollutant sources; if improperly handled, these pollutants 
could also be transported in stormwater runoff to surface waters. For projects with construction sites 
. greater than five acres, the project sponsor would be required to obtain coverage under the statewide 
General Permit for Stormwater Discharges Associated with Construction Activity described above in the 
Setting section. These requirements would potentially apply to future Port development at Pier 70 and 
the Piers 90-94 backlands, as well as to Industry Group project components including Mission Valley 
Rock, British Pacific Aggregates, and Coach USA, all of which would occupy more than five acres, 
although the areas to be disturbed through grading or excavation could be considerably smaller and none 
of these components would require a substantial volume of earthmoving. Depending on -the construction 
schedule for the various projects, the remaining project components under five acres in size may also be 
required to comply with similar regulations, since it is anticipated that Phase II construction stormwater 
requirements will be in place by August 2001. 

Compliance with these regulations and NPDES permit conditions, including development and 
implementation of a site-specific Stormwater Pollution Prevention Plan, would minimize the potential 
for water quality degradation. The SWPPP would typically be required to indicate all pollutant sources 
within the construction area and to identify best management practices to prevent discharge of pollutants 
into stormwater. However, due to the uncertain timing of construction schedules and the Phase II 
construction stormwater requirements, a mitigation measure would require all proposed construction 
sites, regardless of size, would prepare and implement a SWPPP, in order to minimize construction water 
quality impacts. Therefore, with compliance of NPDES General Permit requirements for sites over five 
acres and with implementation of proposed mitigation measures for sites under five acres, water quality 
impacts associated with construction activities would be considered less than significant. 

Water quality impacts associated with demolition and construction in proximity to the Bay are discussed 
in the Waterfront Land Use Plan EIR. Construction activities located on or adjacent to the Bay would 
result in increased potential for spills and for construction materials or debris to enter the Bay and affect 
water quality, particularly if construction activities occur on windy days. Implementation of 
improvement measures identified in the Waterfront Land Use Plan EIR would minimize the potential for 
these impacts and are presented in Chapter IV of this report. Thus, implementation of these measures in 
conjunction with the SWPPP under the NPDES permit requirements discussed above would reduce 
potential water quality impacts to less than significant. 



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HAZARDOUS MATERIALS (p. 128) 

Potential hazardous materials-related effects include, accidental release of hazardous materials or 
petroleum products, such as through a leak from an on-site fuel tank; exposure of workers or the public 
to subsurface soil or groundwater contamination; and exposure of workers or the public, to hazardous 
building materials^ including asbestos, lead-based paint, polychlorinated biphenyls (PCBs), and 
fluorescent lights containing mercury vapors. \ , 

A fuel leak could affect soil, groundwater^ or Bay water quality. However, businesses that store 
petroleum products above ground would be required to comply with the requirements of the City's 
Hazardous Materials Ordinance which includes the requirements for secondary containment and 
preparation of a Spill Prevention Control and Couritermeasure Plan to specify emergency procedures to 
be followed in the event of a spill. Regulations governing underground storage tanks (USTs) require a 
separate permit to operate a UST and include an inspection and monitoring requirement by the 
Department of Public Health (DPH). Further, all establishments that store fuel on-site, whether in above- 
ground or underground tanks, must register with DPH. In the unlikely event that a leak or tank rupture 
did occur, the spill would likely be contained within the secondary containment system for the tank. 
Secondary containment and implementation of emergency response procedures would minimize 
potential exposure of site personnel and the public to petroleum vapors as well as protect the site from 
potential environmental contamination. Compliance with existing regulations regarding storage and spill 
protection would therefore render this impact less than significant. 

Most project components that would involve excavation would be subject to Article 22A of the 
San Francisco Public Health Code, "Analyzing the Soil for Hazardous Wastes" (the "Maher Ordinance"), 
which requires a site-specific investigation, potentially including soil and/or groundwater testing and 
development of health and safety protection measures if applicable, for sites along the historic bay 
margin, including most Port property, where excavation of more than 50 cubic yards of soil is proposed. 
A Maher study has been completed for Pier 92, and could be required for other sites prior to 
construction. Compliance with existing Article 22A regulations would render potential impacts of 
subsurface contamination less than significant. 

Hazardous building materials may be encountered during renovation or demolition of existing buildings. 
If fria'ble or iionfriable asbestos is present, there is a potential for release of airborne asbestos fibers when 
the asbestos-containing materials are disturbed, unless proper asbestos abatement precautions are taken. 
Such a release could expose the public and construction workers to airborne asbestos fibers. Compliance 
with the California Health and Safety Code and Bay Area Air Quality Management District regulations 
concerning asbestos, and proper inspection and, if necessary, removal of asbestos would avoid any 
potential significant effects. '' 

If lead-based paint is present and has delaminated of chipped from the surfaces of the building materials, 
there is a potential for the release of airborne lead particles during construction, renovation, or other 
activities that would disturb loose or peeling paint, unless proper lead abatement procedures are 



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followed. Construction and renovation activities must comply with Chapter 36 of the San. Francisco 
Building Code, Work Practices for Exterior Lead-Based Paint. Where there is any work that may disturb 
or remove lead paint on the exterior of any building built prior to December 31, 1978, Chapter 36 • 
requires specific notification and work standards, and identifies prohibited work methods and penalties. 
These regulations and procedures required as part of the San Francisco Building Code would ensure that 
potential impacts due to lead-based paint would be reduced to a level of insignificance. • 

If PCBs are present in the building to be demolished, leakage could expose workers to unacceptable 
levels of PCBs (greater than 5 parts per million, based on Title 22, California Code of Regulations). ■ 
Removal of fluorescent light tubes could result in exposure to mercury vapors if the lights are broken. 
Project sponsors would ensure that survey (s) for hazardous building materials is completed prior to 
renovations of an existing building, and that removal and disposal of transformers and light tubes, if 
required, is completed. This would reduce impacts related to hazardous building materials to a less-than- 
significant level. ' 

BIOLOGICAL RESOURCES (p. 139) 

Construction of the proposed Illinois Street Bridge across Islais Creek would cause both short-term 
construction impacts and longer-term changes in habitat ttiat would have minor, and less-than- 
significant, effects in the immediate vicinity of the proposed bridge. Construction impacts would include 
primarily water quality effects from disruption of bottom sediments when material is dredged for 
placement of bridge abutments or other in- water structures. Sediment suspension would cause some 
increases in turbidity and resettling of fine sediments that can smother and interfere with feeding or 
respiration of less mobile organisms in the project area. If construction occurred during the Pacific 
herring spawning season (i.e., from December to February), any eggs attached to the wharf/pilings 
adjacent to the proposed construction site, or any newly hatched larvae, may be subject to smothering or 
other negative effects of the sediments released from dredging activities. Effects on herring could be 
mitigated by avoiding activities during the December-February spawning season, if feasible. If activities 
are proposed for December through February, a qualified biological monitor should survey the area to 
determine if spawning herring are present and, if so, the contractor would temporarily cease work (see 
Mitigation Measure F. la, p. 154). 

In addition to the potential for physical effects from construction activities, resuspension of bottom 
sediments can release contaminants into the water column that are harmful to aquatic life. Of concern 
would be highly organic materials that would increase the oxygen demand and possibly reduce oxygen 
levels in the adjacent waters sufficiently to harm some less mobile Organisms. If dredging were required, 
the U.S. Army Corps of Engineers would require sediment analysis to determine the potential for 
contamination from any dredged sediments and specify disposal and dredging methods to accommodate 
the sediment character. Effects would be less than significant because of the relatively small area that 
would be affected. 



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Longer term effects from bridge construction would include any displacement of existing soft bottom or 
other natural habitat by bridge abutments and/or other structures placed in, or along the water edge. This 
would remove habitat for some burrowing invertebrates such as clams and tubeworms, which are, in 
turn, forage for resident fishes such as the white croaker. This habitat would be replaced with concrete 
and thus offer "hard surface" habitat for attached organisms such as mussels and Pacific herring eggs. 
Whether the habitat is improved or reduced in value, the change would be very minor because of the 
generally degraded quality of the existing habitat and the small quantity of change in relation to the 
overall habitat of this kind in the area. 

There are wetlands located in the Southern Waterfront but outside the vicinity of the proposed Illinois 
Street bridge. The Waterfront Plan EIR notes that wetlands at Pier 98 (now known as Heron's Head 
Park) and at Pier 94 (Seawall Lot 352) could be adversely affected by contaminated runoff and by public 
access. Concerning the former, Section IILD, Hydrologyj of this SEIR concludes that effects, would be 
less than significant. Concerning the latter. Heron's Head Park has been constructed with numerous 
signs warning visitors to stay out of wildlife habitat areas, while the Pier 94 wetlands would continue to 
be located in areas surrounded by industrial uses and therefore would not be subject to public access. 
Furthermore, the Waterfront Plan calls for "reserv[ing] or improv[ing] areas which will provide 
opportunities for the protection of wildlife habitat and for passive and active recreational areas." Project 
components would not encroach into the existing wetlands, and thus no significant effect would occur. 

C AREAS OF CONTROVERSY ANDiSSUES TO BE RESOLVED 

Perhaps the greatest area of controversy involves cpnmiunity concern about potential impacts, 
particularly related to air quality, of increased industrial activity near the Bay view - Hunters Point 
neighborhood. In particular, Comrnunity groups and residents have expressed concern over existing and 
future cardio-respiratory health effects related to emissions from project components and other 
development in the neighborhood. Other concerns expressed in responses to the Notice of Preparation 
for the SEIR included questions about the mix of land uses, in particular related to whether housing 
should be included on one or more sites in or near the project area, and whether one or more project 
components could conflict with potential future housing and/or commercial development. 

D. MITIGATION MEASURES (p. 143) 

This section includes mitigation measures for topics analyzed in this SEIR. Additional mitigation 
nieasures from the 1997 Waterfront Plan EIR are included in Chapter IV, p. 143. 

TRANSPORTATION 

MEASURES IDENTIFIED IN THIS SEIR 

B.l To mitigate 2015 conditions, monitor traffic level of service (LOS) conditions at the intersections 
listed below in Table S-1. At such time as warranted by traffic conditions (i.e., a degradation of 



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the p.m. peak-hour service level to an unacceptable LOS E or F), institute the identified 
improvements or implement another measure determined at that time to be adequate to mitigate the 
degradation in level of service. 

TABLE S-1 

MITIGATION MEASURES FOR INTERSECTION LEVELS OF SERVICE 



Intersection- 



Mitigation Measure 



2015 Level of Service 
A.M. Peak Hr. P.M. Peak Hr. 

Project LOS w/ Project LOS w/ 
LOS Mitig. LOS Mitig. 



Third /25 th 
Streets t 



Illinois / 25th 

Streets tt 
Pennsylvania / 
' 1-280 SB 

On-Ramp tt 
Pennsylvania / 

Cesar Chdyez 

Streets 
Third / C^sar 

Chavez Streets 



Illinois / Cdsar 
Chivez Streets 



Amador Street / 
Cargo Way 



• Restripe the east- and westbound approaches to 
provide left-turn lanes. 

• Revise signal timing to provide protected east- and 
westbound left-turn phases. 

• Install traffic signal. 

• Install traffic signal. 



►'Reconstruct the roadway to provide an exclusive 
northbound right-turn lane ("free" right-turn). 

» Add a sfecond northbound left-turn lane and an 
additional lane in each direction to the western 
approach on Cesar Chavez Street. (This would 
require the acquisition of additional right-of-way on 
Third Street at the southeast comer of the intersection, 
where there is an existing building.) 

» Install traffic signal. . 

» Restripe the northbound and southbound approaches 
to provide left-turn lanes and shared right-through 
lanes. 

» Restripe the eastbound and westbound approaches to 
provide a shared left-through lane and a shared 
through-right lane. 

» Install traffic signal. 

» Restripe the southbound Amador Way approach to 
provide a.left-tum lane, a shared left-through lane, and 
a right-turn lane. ■ 



D 

.B(C) 
B(C) 



B 
B 

D 



D 



D 

A 
B 

D 

D 



t - Mitigation required only in p.m. peak hour. 

$ - LOS and delay reported for overall intersection; LOS in parientheses is for critical movement, when worse than 
overall LOS. 

SOURCE: Wilbur Smith Associates 



B.2 At such time as specific mixed-use or other non-industrial projects generating more than 100 daily 
vehicle trips are approved and occupied at the Pier 70 Mixed-Use Opportunity Area and the 
Pier 90-94 backlands, the Port shall develop'a Transportation Systems Management (TSM) Plan, 
■ and potentially a Transportation Management Agency (TMA) that would consist of Port staff, Port 
tenants, property owners, and project occupants. The goals of the TSM Plan and the TMA shall be 



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to reduce, to the maximum feasible extent, the use of single-occupancy automobile traffic and 
encourage other forms of travel to and from work, including transit, carpooling and ridesharing, 
bicycle, walking, and other means. 

B.3 The Illinois Street bridge that is proposed by the Port would improve operating conditions at Third 
Street and Cargo Way to an acceptable level of service (LOS C in the a.m. peak hour and LOS D in 
the p.m. peak hour), compared to conditions without the proposed bridge. 

MEASURES FROM THE 1997 WATERFRONT PLAN FEIR, AS APPROVED BY THE 
PORT COMMISSION, JUNE 1997 (Included in the Project) 

B.4 The Port shall comply with requests from the Major Environmental Analysis section of the 

Planning Department to analyze intersection levels of service for existing and future conditions at 
intersections that may reasonably be expected to be affected by each future development project, 
and shall identify and implement appropriate mitigation measures. 

■Any such transportation analysis would need to be coordinated with monitoring of the Congestion 
Management Program network, conducted biennially by the San Francisco County Transportation 
Authority as the designated Congestion Management Agency for San Francisco County. Within 
the WLUP Project Area, The Embarcadero, King, Third and Fourth Streets are all included on the 
Congestion Management Program network. A number of intersecting streets (North Point, Bay, 
Broadway, Washington, Clay, Cesar Chavez, and Evans west of Third) are also included on the 
CMP network. The Authority would conduct monitoring activities along these facilities, but only 
in the context of determining changes in Level of Service for arterial segments (not for individual 
intersections). Degradation of the Level of Service for one or more individual intersections within 
an arterial segment, to Level of Service "F" or to below some other designation deemed to be 
acceptable, could also degrade the segment Level of Service. The degree of impact to the segment 
may not be sufficient for the Transportation Authority to identify a "deficiency" under the CMP 
process (Level of Service "F" for the entire segment), even though the Port or City could impose 
mitigation requirements for developers of projects that would. have a significant impact on 
individual intersections. Based on the transportation analysis for this EIR, cumulative 
development along the Waterfront might cause degradation of a particular segment of the CMP 
network to fall to "F," thereby triggering a finding of deficiency requiring formulation of a 
Deficiency Plan, and implementation of that Plan under the CMP processes identified by the 
Transportation Authority. The Authority could, in this circumstance, identify the Port as the lead 
agency for development of the Deficiency Plan and for implementation of any corrective 
measures, and the Port could require sponsors of specific development projects that contribute to 
cumulative congestion to participate in improvement and mitigation measures. ( 1997 FEIR 
Measure DA) . ' 

B.5 To help induce shifts from vehicles to transit and thereby partially mitigate local intersection 
impacts and regional highway implacts, the Port could require and/or institute Transportation 
Demand Management Programs among developers of major trip generators, as a condition of lease 
approval. This would apply in particular to future Port development at Pier 70 and the Pier 90-94 
backlands. " 

Sucl) programs typically target primarily commute trips, with various educational, assistance and 
incentives measures to encourage carpooling and vanpooling, and transit use. These measures may 
be accompanied by such "disincentives" to lOw-occupant private vehicle use as restricting the 



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amounts and/6r location of parking made available to employees, and charging higher fees for all- 
day parking. Also typical are measures designed to shift time of conrunute travel to the "shoulders" 
of the peak, and/or to encourage less trip making through alternative work schedules and 
telecommuting. The effectiveness of these programs is variable, but they are most appropriate and 
effective when there are substantial constraints to vehicular travel, circulation and storage coupled 
with suitable options such as excellent transit accessibility. San Francisco in general, and its 
downtown and portions of the waterfront in particular, exhibit this combination of factors. 

The Port could also design and implement similar programs which would target non-commute 
travel. An example of the type of measure which might be included is the issuance of discount, 
admission to some uses, or reductions in the price of services and/or merchandise, upon 
presentation of a valid transit transfer or, other proof of transit use payment. Additionally, a free 
shuttle along The Embarcadero could be a part of this type of program, and would help to alleviate 
local auto congestion. (7997 FEIR Measure D-7) 

AIR QUALITY 

Measure B.3, above, would reduce but not eliminate the project's contribution to potentially significant 
air quality impacts. The mitigation measures in this section would further reduce but not eliminate the 
project's contribution to potentially significant air quality impacts. 

MEASURES INCLUDED IN THE PROJECT 

C.l Each of the Industry Group construction aggregate industry project components, which would 

represent "stationary sources" of particulate emissions, shall include "best available control . • 
technology" (BACT) to control emissions, consistent with current regulations. For aggregate-handling 
operations (Bode Gravel, Mission Valley Rock, RMC Pacific, British Pacific Aggregates), this . 
includes maintaining a moisture content in the aggregate that is high enough to eliminate PM-10 
"fugitive" emissions (wind-blown dust that could otherwise escape into the surrounding air). A water 
spray system shall be installed at each aggregate-handling facility, including Bode Gravel, Mission 
Valley Rock, RMC Pacific, and British Pacific Aggregates. Fine aggregate material (sand) shall be 
maintained with a moisture content of approximately 5 percent, because such material with a moisture 
content of 4.5 percent or more produces virtually no fugitive emissions. Coarse aggregate (gravel) 
shall be kept damp on the surface, which would also effectively eliminate fugitive dust. Aggregate 
shall be stored in bunkers at ready-mix and asphalt plants, rather than open piles, with water spray 
(including the use of surfactants, as necessary, to bind the water and dust to the aggregate) applied to 
maintain adequate moisture content to control emissions at both production and shipping/storage 
operations. ISG Resources, which would handle fly ash, a finer, more powdery material than 
aggregate, shall install BACT dust collection equipment to accommodate truck and rail transport and 
shall use pneumatic equipment to control dust emissions during the transfer of fly ash. . 

C.2 The asphalt plant proposed by Mission Valley Rock (and potentially the British Pacific asphalt . 
, plant) shall include controls on the drum mixer where the asphalt cement and aggregate are mixed. 
Drum mixer(s) shall be fired with natural gas, consistent with Best Available Control Technology 
(BACT) recommendations, and particulate emissions from the aggregate drying and mixing 
process shall be controlled with a fabric filter, also consistent with BACT. Such filters can achieve 
control efficiency of greater than 99 percent. 



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C.3 Consistent with the City's Clean Ak Program (established by Ordinance 258-99, adopted 

October 15, 1999), it is City policy to "foster, promote, and encourage the use of low emission 
[alternative fuel vehicles] and [zero emission vehicles] by developing infrastructures to support the 
use of these vehicles." Under the ordinance, the City is to (1) assess the need for a network of 
natural gas fueling stations accessible to the public; (2) site and develop at least five such facilities, 
by public and/or private entities; (3) install 50 publicly accessible electric vehicle charging stations 
in City garages, lots, or other sites; (4) develop a plan for additional charging stations and related 
infrastructure; (5) buy and lease ultra-low and zero emission vehicles for City department use; (6) 
identify and convert diesel bus lines to electric service; (7) develop a plan to phase out older diesel 
buses; (8) develop a plan and incentives to encourage larger private vehicle fleets to convert their 
fleets to very low or zero emission vehicles; and (9) develop a car sharing program in high density 
neighborhoods. 

Consistent with the City's Clean Air Program, the Port shall require that all tenants make a good 
faith effort to engage in operational practices sensitive to the environment and the neighboring 
community. In furtherance of this, the Port shall require that tenants operating a fleet of vehicles 
investigate the. potential for use of low- or zero emission vehicles and implement measures to 
reduce vehicle emissions to the maximum feasible extent. Options may include, but not 
necessarily be limited to, the use of low-emission diesel fuel (including low-sulfur diesel); the use 
of catalytic particulate traps for diesel-powered engines that are currently under study by the 
California Air Resources Board; the use of other emerging technologies to reduce diesel particulate 
emissions; and use of electric vehicles. The Port shall also require that tenants operating diesel- 
powered stationary equipment investigate similar options. Tenants shall investigate retrofitting 
existing engines and purchase of new engines. The Port shall further require that tenants who 
work with independent trucking contractors encourage those contractors to make similar efforts, 
including, if reasonably feasible, providing such truckers with economic incentives to retrofit 
equipment or take other measures as may be necessary to use low-emission fuels. As an economic 
incentive to minimize diesel emissions from Port property, the Port shall contribute towards the , 
incremental costs incurred by its tenants for Port-approved equipment and improvements in 
. furtherance of this measure. Finally, the Port shall establish a schedule by which tenants described 
above shall report to the Port on progress in investigating reduced-emission engines. 

C.4 At such time as specific mixed-use or other non-industrial projects generating more than 100 daily 
vehicle trips are approved and occupied at the Pier 70 Mixed-Use Opportunity Area and the 
Pier 90-94 backlands, the Port shall develop a Transportation Systems Management (TSM) Plan, 
and potentially a Transportation Management Agency (TMA) that would consist of Port staff. Port 
tenants, property owners, and project occupants. The goals of the TSM Plan and the TMA shall be 
to reduce, to the maximum feasible extent, the use of single-occupancy automobile traffic and 
encourage other forms of travel to and from work, including transit, carpooling and ridesharing, 
bicycle, walking, and other means. 

C.4A To regulate the production of concrete or asphalt material consistent with the volumes analyzed in 
the Southern Waterfront SEIR, any lease for concrete or asphalt batching operations on Port 
property shall include a provision setting forth the maximum production volume allowed under the 
lease, such that the cumulative total of production volumes of such batching operation leases shall 
not exceed the volumes assumed and analyzed in the SEIR, 



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To monitor production volumes that may occur on Port property, the Port shall require as a 
condition of each lease that each tenant provide annually an audited account of the concrete and/or 
asphalt production volumes provided by each concrete or asphalt production business. The Port 
shall incorporate this information in an annual report to the Port Commission. 

Should, any existing tenants propose to increase production above the amounts stipulated in the 
lease, such change would require an amendment to the lease, and would be subject to further 
environmental review by the San Francisco Planning Department's Major Environmental 
Assessmerit (MEA) division. In determining whether fuirther environmental impact analysis will 
be required, MEA will consider the production levels cited in the Port's report and any emission- 
reducing improvements that may have been incorporated into the on-site operations (stationary 
sources), and trucks and other vehicles associated with the operations (mobile sources). 

REVISED MEASURE FROM THE 1997 WATERFRONT PLAN FEIR, AS APPROVED BY 
THE PORT COMMISSION, JUNE 1997 (Included in the Project) 

C.5 The Port shall require that project sponsors direct construction contractors to implement a dust 
abatement program to reduce the contribution of project construction to local PM-10 
concentrations. Elements of this program, which is currently applied to all Port tenants, include 
the following: ' , -. 



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• Water internal roadways and unpaved construction areas just prior to the morning and 
evening peak traffic periods (to limit the potential for major roadway traffic to entrain dust), 
limit speeds to 10 mph, and sweep paved internal roads after the evening peak period. 

• In addition, water active sites (e.g., where demolition, excavation or other earth work is 
underway) at least twice per day. Increase the frequency of watering when wind speeds 
exceed 15 miles per hour. Suspend all excavating arid grading operation when instantaneous 
gusts exceed 25 miles per hour. 

• Replace ground cover in disturbed areas as quickly as possible. 

• Enclose, cover, water twice daily, or apply soil binders to exposed stockpiles of sand, gravel, 
and dirt. 

• Install gravel at construction equipment entrances to unpaved areas to prevent tracking of 
dirt and mud onto streets. , . < 

• Sweep paved access roads, parking areas, and construction staging areas, at the end of day 
(with water sweepers), and sweep adjacent City streets if any visible soil material is carried 
over to these streets. 

• Cover all trucks hauling dirt, sand, soil, or other loose materials. Maintain at least six inches 
. of freeboard between the top of the load and the top of the trailer. 

• Sweep up dirt or debris spilled onto paved surfaces immediately to reduce resuspension of 
particulate matter through vehicle movement over these surfaces. 

• Designate a person or persons, to Oversee the implementation of a comprehensive dust 
control program and to increase watering, as necessary. 

• Maintain and operate construction equipment so as to minimize particulates from exhaust 
emissions. During construction, require contractors to operate trucks and equipment only 
when necessary , Equipment should be kept in good condition and well-tuned, to minimize 
exhaust emissions. . 

Ordinance 175-91, passed by the Board of Supervisors on May 6, 1991, requires that non-potable 
water be used for dust cotitrol activities. Therefote, the project sponsor shall require that the 
contractor(s) obtain reclaimed water from the Clean Water Program for this purpose. 

This mitigation measure also would fedtice demolition-related impacts regarding lead paint 
chips/lead dust. The project sponsor shall also be required to comply with Chapter 36 of the 
San Francisco Building Code, Work Practices for Exterior Lead-Based Paint, enforced by the 
San Francisco Department of Building Inspection. 



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MEASURE IDENTIFIED IN THIS SEIR 

C.6 Consistent with the construction-period dust abatement program described in Mitigation Measure 
C.5, the Port shall require that Industry Group components and other aggregate-related tenants 
employ dust abatement procedures including, but not necessarily limited to, the following: 

• installation and operation of truck wheel-washing systems at plant exits for facilities that 
operate on unpaved surfaces; 

• daily street sweeping on streets surrounding aggregate-related facilities; and 

• clearly posting on the exterior wall or fence of such facilities a company telephone number 
for citizens to call with dust, noise, or other operational complaints, and designation of a Port 
staff contact for same. 

No other feasible mitigation measures have been identified that would reduce the project's total regional 
emissions to a level below Bay Area Air Quality Management District thresholds, or eliminate the 



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project's contribution to potentially significant cumulative impacts from all existing (unquantified) and 
future (unknown) emissions sources. 

HYDROLOGY 

MEASURES INCLUDED AS PART OF THE PROJECT 

D.l For construction sites of less than five acres of disturbed area, the, contractors shall be required to 
prepare and implement a Storm Water Pollution Prevention Plan (S\yPPP) similar to that required 
under the statewide General Permit for Stonn Water Discharges Associated with Construction 
Activity. The SWPPP would include site-specific information to identify and evaluate sources of 
pollutants associated with industrial activities and to identify and implement site-specific best 
. maiiagement practices to reduce or prevent pollutants associated with industrial activities in 
stormwater discharges. Best management practices may be non-structural (e.g,, activity schedules, 
maintenance procedures, prohibitions of pi-actices) or structural (e.g., treatment measures, runoff 
controls, overhead coverage). Elements of the SWPPP shall include the following: 

• measures for erosion and sediment controls . 

• methods for construction waste handling and disposal, and 

• post-construction erosion and sediment control requirements. ; 

D.2 To minimize the potential for water quality degradation from stormwater runoff, the Port shall 
require that all tenants and developers, including interim lessees such as the Industry Group 
members, implement source control Best Management Practices consistent with those identified in 
the Industrial / Commercial Storm Water Best Management Practices Handbook (Stormwater 
Quality Task Force, 1993). Measures shall include, but are not limited to, the'foUowing (some of 
which are proposed as part of one or more Industry Group components): 

• prohibiting discharge of process water to storm drains or otherwise directly to the Bay or Islais Creek; 

• separating stormwater from process water, such as concrete truck washout water and truck wash water, 
through the use of berms and other features, and ensuring that treated stormwater to be discharged to 
the Bay meets applicable permit and regulatory standards, including pH (acidity or akalinity); 

• for Industry Group components that would use water in dust control, creation of settling basins or 
similar features that would allow sediment to be removed from water prior to reuse and/or 
discharge; 

• daily street sweeping of surrounding streets arid, for facilities that operate on unpaved surfaces, 
installation and operation of truck wheel- washing systems at aggregate-related plants; 

• employing appropriate containment measures for fuel, asphalt cement, and other hazardous 
materials stored on-site, to capture potential spills (including at on-site fueling areas); 

• installing and maintaining grease and sediment traps at vehicle maintenance and washing areas 
to prevent contaminated runoff from entering the storm drains or Bay; 

• installation of sediment containment systems around outdoor aggregate storage facilities to limit 
sediment entering stormwater runoff, and covering such storage areas if feasible to limit 
stormwater infiltratiqn; 

. creation of a designated w&sh-out area for concrete trucks to prevent concrete slurry from reaching 
the Bay; and 

• cover any open conveyors in use over the Bay (i.e., between piers and ships and barges) to minimize 
the potential for direct sediment spill to the Bay. 



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REVISED MEASURES FROM THE 1997 WATERFRONT PLAN FEIR, AS APPROVED 
BY THE PORT COMMISSION, JUNE 1997 (Included in the Project) 

D.3 As part of permit and lease requirements for future Port development projects, runoff from 

stormwater at new or re-developed facilities located outside of the City' s combined sewer System 
shall be, at a minimum, subject to appropriate treatment such as on-site oil/water separators and/or 
sediment traps, depending on the nature of the pollutants that may be in the runoff, so that 
stormwater runoff is treated prior to discharge and that there is no direct, untreated discharge to the 
Bay or Islais Greek. Stormwater runoff from future Port development sites shall not be directed to 
the City's combined system, as originally contemplated in the Waterfront Plan EIR, and the 
volume of stormwater flows from the project area to the City's combined sewer system shall 
remain the same as at present, unless the increased flow to the combined system would result in no 
additional volume of combined sewer overflows. 

D.4 Sponsors of individual project components, including members of the Industry Group, shall be 

required to implement appropriate Best Management Practices for stormwater pollution prevention 
throughout the life of each lease and shall be required to monitor stormwater quality in accordance 
with the requirement of the statewide General Permit for Discharge of Industrial Stormwater. 

D. 5 Sponsors of individual project components, including members of the Industry Group, shall 

conduct water quality monitoring during construction of facilities on or adjacent to the Bay to 
minimize effects of construction activities on water quality. In order to minimize potential for 
spills, construction materials or debris to enter the Bay and affect water quality, site specific 
construction methods and precautions, such as limiting activities on days of strong- winds, could be 
included in the contractor's construction specifications to minimize effects on water quality. 
Demolition of structures with lead -based paint should include physical precautions to ensure that 
paint dust and chips do not enter thie Bay. 

HAZARDS 

MEASURES INCLUDED AS PART OF THE PROJECT 

E. l Accidental Release of Hazardous Materials or Petroleum Products 

In accordance with the Hazardous Materials Ordinance, the sponsor of each Industry Group or Port 
project component shall ensure that a Hazardous Materials Business Plan is prepared for each of 
the project components involving the use of petroleum products or hazardous materials. The plan 
would specify methods for handling and storage of the§e including containment, site layouts, and 
emergency resporvse and notification procedures for a spill or release. 

The project sponsor(s) shall ensure that a Spill Control and Countermeasure Plan is prepared for 
any project involving the aboveground storage of petroleum products. The plan would include 
requirements for appropriate spill containment or equipment to divert spills from sensitive areas, a 
discussion of facility-specific requirements for the storage system, inspections and a record 
keeping system, security for the system, and personnel training. The project sponsor(s) would also 
comply with the state requirement that above-ground storage tanks subject to federal regulations 
are registered with the Regional Water Quality Control Board. 



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E.2 Hazardous Materials in Soil 

E.2a Because the Bode Gravel and Mission Valley Rock projects would be constructed bayward of the 
historic high tide line and would involve the excavation of at least 50 cubic yards of soil, the 
sponsors of those component's, shall ensure that the contractors comply with the requirehients of 
Article 22A, "Analyzing the Soil for Hazardous Wastes." In accordance with the approved site 
mitigation report for this project component, the site would be capped with an asphalt or concrete 
slab and structures. Upon completion of capping, a certification report would be prepared to 
document construction activities and a maintenance report would be prepared specifying 
procedures to be followed to control exposure to the subsurface soil following construction of the 
proposed project. These reports would be submitted to the San Francisco Department of Public 
Health for review and approval to ensure regulatory compliance. 

For any other Industry Group or Port-sponsored project components for which Article 22A would 
apply (including the Illinois Street bridge, if applicable), a site history report, soil investigation, 
and soil analysis report would be completed to identify potential hazardous materials at this site. 

If indicated by thp results of the soil investigation, the project sponsor would ensure that the 
contractors for each project prepare a Site Mitigation Report in compliance with Article 22A if 
warranted by the levels of hazardous materials identified in the soil. The plan would include 
measures for the handling of soil produced during excavation, to control dust and runoff during 
construction, and to characterize soil for off-site disposal purposes. Upon completion of 
construction, the project sponsor would ensure that the construction contractors prepare a 
certification report certifying that either (1) no hazardous wastes present in the soil present an 
unacceptable risk and that no mitigations are required; or (2) all mitigation measures specified in 
the site mitigation report have been completed and that completion of the mitigation measures has 
been verified through follow up sampling and analysis, if required. All reports would be submitted 
to the San Francisco Department of Public Health (DPH) for review and approval to ensure 
regulatory compliance. 

The project sponsor shall prepare and submit to DPH a site-specific Safety and Health Plan (SHP) 
that would address worker safety concerns resulting from potential contaminants on the site. The 
SHP would include provisions for responding to unknown hazardous materials site conditions that 
could be encountered during construction. 

If the soil investigation demoiistrates that hazardous wastes present in the soil could be at levels 
that pose an unacceptable health risk, the project sponsor would ensure that appropriate site 
investigations and risk evaluations are performed to evaluate potential human health risks related 
to any hazardous substances left in the soil or groundwater after completion of construction. The 
investigations, risk evaluations, and any required remedial actions would be implemented under 
the oversight of the appropriate regulatory agency(ies) to ensure compliance with applicable laws 
and that the public health and safety are protected. 

E.2b For all projects where subsurface contamination is identified, the project sponsor would ensure that 
from the time that ground surfaces are exposed until the time that all remedial activities have been 
completed, a fence is erected around the area where chemicals have been identified in the soil and 
site access is restricted to necessary personnel. Warning signs prohibiting access by the general 
public onto the project site would be posted at all construction access points. Access would be 
limited to authorized personnel only. 



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1. SUMMARY 



Dust-control measures applicable for air quality impacts would also minimize the potential public 
health impact associated with dust emissions and air quality pollutants. (See also Air Quality 
Mitigation Measures.) 

MEASURE PROPOSED BY THE PORT AS PART OF THE PROJECT 
E.3 Soil Disposal 

The Port shall contract for or require that Port tenant(s) contract for disposal of any portion of the 
soil pile on the Bode and Mission Valley Rock sites at Pier 92 that cannot be reused for 
construction projects in accordance with applicable waste disposal regulations. Such reuse would 
also require approval of the San Francisco Department of Public Health. 

REVISED MEASURE FROM THE 1997 WATERFRONT PLAN FEIR, AS APPROVED BY 
THE PORT COMMISSION, JUNE 1997 (Included in the Project) 

E. 4 Hazardous Building Materials 

The project sponsor for each Industry Group component and each future Port development 
component involving demolition or renovation of existing facilities shall ensure that hazardous 
building material survey(s) for asbestos, PCB -containing equipment (including transformers, 
elevator equipment, and other applicable equipment), hydraulic oils, fluorescent lights, and lead- 
based paint is conducted prior to the start of demolition or renovation, for each such project 
component. The survey(s) would be completed by a Registered Environmental Assessor or a 
registered engineer prior to construction or demolition activities. If any friable asbestos-containing 
materials or lead-containing materials are identified, adequate abatement practices, such as 
containment and/or removal, would be implemented prior to demoUtion or renovation. Detailed 
requirements for the assessment, abatement, and disposal of hazardous building rnaterials are presented 
in Appendix F. Any PCB-containing equipment or fluorescent lights containing mercury vapors 
would also be removed and disposed of properly. 

Any hazardous materials discovered through building survey(s) would be abated according to 
federal, state, and local laws and regulations. In particular, the project sponsors will be required to 
comply BAAQMD requirements for the removal of friable and non-friable asbestos containing 
materials as well as other requirements of Cal/OSHA, BAAQMD and the Contractors Licensing 
Board for abatement of asbestos prior to demolition. 

BIOLOGICAL RESOURCES 

REVISED MEASURES FROM THE 1997 WATERFRONT PLAN FEIR, AS APPROVED 
BY THE PORT COMMISSION, JUNE 1997 (Included in the Project) 

F. la The Port could limit dredging operations and other construction activity in connection with the 

Illinois Street Bridge to between March 1 and November 30 to eliminate any potentially significant 
impacts of dredging or pier repair/replacement on the Pacific herring fishery. The Port would 
specify in construction contracts that, in exceptional cases where dredging operations or bridge 
construction must conflict with the herring season, the following conditions must be fulfilled: 



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• A professional fisheries biologist or other individual sufficiently competent to identify 
herring spawning activity would monitor the project site daily at any time when dredging or 
other in- water construction activity were taking place. 

• In the event that the on-site monitor detects herring spawning at, or within 200 meters of 
dredging or other in-water construction activity, the monitor would inmiediately notify the 
Environmental Review Officer and the project construction manager, who would halt the 
dredging or other construction activity for a minimum of 14 days, or until the monitor 
determines that the hatch has been completed and larval herring have left the site. The 
dredging or other construction activity may resume thereafter. 

F.ib Project sponsors of Industry Group project components would similarly limit dredging operations 
and pier repair/replacement to between March 1 and November 30 to eliminate any potentially 
significant impacts of dredging or pier repair/replacement on the Pacific herring fishery. In. 
exceptional cases where dredging operations or major pier repair/replacement operations (beyond 
routine maintenance) must conflict with the herring season, the project sponsor(s) would consult 
with the permitting agencies, including but not necessarily limited to the U.S. Army Corps of 
Engineers, Bay Conservation and Development Commission, State Department of Fish and Game, 
and Regional Water Quality Control Board. The sponsor(s) would comply with specific 
monitoring requirements established by these and other agencies to avoid impacts on the herring 
. fishery. 

F.2 Prior to demolition or renovation of any abandoned building between August 15 and October 15, 
or between February 1 and May 1, project sponsor(s) would ensure that survey(s) are conducted 
. during the same period by a qualified bat biologist. If no Townsend's western big-eared bats are 
found during the survey (s), no additional mitigation is required. 

If Townsend's western big-eared bat, a California Species of Special Concern, is found during an 
August - October survey, appropriate exclusion devices approved by CDFG & USFWS should be 
installed by a qualified bat biologist. Once the bats have been excluded, demolition may occur. 

If Townsend' s western big-eared bats are found during a February - May survey, demolition 
. should not take place until the end of the nursery season in August. Exclusion devices should be 
placed by a qualified bat biologist in accordance with CDFG and USFWS. 

E. ALTERNATIVES TO THE PROPOSED PROJECT (p. 168) 

The Waterfi-ont Plan EIR analyzed two alternative development outcomes that could occur under the 
Waterfront Land Use Plan. Those alternatives are hereby incorporated by reference. This SEIR does not 
evaluate an off-site alternative that would place the proposed Industry Group uses elsewhere in 
San. Francisco, because Port jurisdiction is limited to a band along the City's bayfront. However, the 
alternatives analyzed below do include both differing combinations of Industry Group uses and 
variations on the assumptions concerning future Port development to provide for a range of potential 
outcomes for the Southern Waterfront subarea, consistent with the adopted Waterfront Land Use Plan. 



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ALTERNATIVE A: NO PROJECT 

This alternative would entail no change to the project area, which would remain in its existing condition. 
None of the Industry Group project components would be implemented, and the Illinois Street 
Multimodal Bridge would not be built. Because several of the Industry Group components are proposed 
bin response to the need for Industry Group members to relocate from existing loc&tions, this alternative 
would necessarily involve displacement of those uses elsewhere in San Francisco, including the existing 
Bode Gravel and RMC Pacific concrete plants and the Coach USA bus operation. Those uses could 
relocate elsewhere in the City, although particularly in the case of the concrete plants, the potential 
locations are limited by the heavy industrial nature of the uses. It would be speculative, however, to 
project potential relocation sites for these uses, which could be forced to move out of San Francisco 
under this alternative. 

Also under this alternative, the future development envisioned for the Pier 70 Mixed-Use Opportunity 
Area, the Pier 70 Maritime Reserve area, the Pier 90-94 backlands, and the Western Pacific site (except 
for the already approved Muni Light Rail storage and maintenance facility) would not necessarily occur 
as described in this SEIR. There might still be some development on these sites in the future, consistent 
with the Waterfront Land Use Plan, and subsequent environmental review could be- required if projects 
were to differ substantially from those described in this document. Increased cargo shipping could also 
occur in the Southern Waterfront, consistent with the Waterfront Plan. 

This alternative would result in little or no short-term (Phase I) increase in automobile or truck travel, as 
would occur with implementation of the proposed project. Long-term (2015) effects on local < 
intersections would be less substantial than would occur with the project, but could still be significant, 
depending on the volume of future development on Port lands and increased cargo shipping. Therefore, 
this alternative would result in significant traffic impacts in 2015, although to a lesser degree than would 
the project. Emissions of criteria air pollutants would be less substantial than with the project, 
particularly in the short-term< By 2015, depending on the increase in cargo shipping at tl]ie Port, 
emissions of NO^ could be significant, as with the project, although the volume of emissions would be 
less. This alternative. would also.resu.lt in a significant cumulative effect related to air quality. Like the 
project, however, this alternative would result in less-than-significant effect with regard to local 
concentrations of carbon monoxide, PM-10, and.diesel particulate. Effects related to hydrology would 
be less substantial than those of the project, and would be less than significant with the mitigation 
measures revised from the Waterfront Plan EIR to control stormxYater runoff. It is likely that futilre 
development on Port lands would result in increase in impervious surface that could result in an increase 
in stormwater runoff to the Bay, although less than with the project. Similarly, the No Project 
Alternative would result in less potential for exposure to and accidental release of hazardous materials 
than \yould the project, although any potential impacts would continue to be mitigated, as with the 
project, by reliance on existing regulations, including Article 22A of the City Public Health Code. As 
with the project, impacts would be less than signifTcant with mitigation. 



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I. SUMMARY 



The No Project Alternative would be environmentally superior to the project because it would avoid 
much of the environmental impact of the project. The No Project Alternative would not meet the project 
objectives. ■ , 

ALTERNATIVE B: REDUCED:SCALE ALTERNATIVE 

This alternative would include all Industry Group facilities with the exception of the proposed Mission 
Valley Rock asphalt plant and the Coach USA bus storage facility, as well as those shipping-related 
components that are proposed to provide for an anticipated shift in the supply of construction aggregate 
from local sources to out-of-area sources. Included would be two concrete plants (Bode Gravel at 
Pier 92 and RMC Pacific at Pier 80); Mission Valley Rock's aggregate import terminal at Pier 92 (but 
not Mission Valley's proposed asphalt plant; British Pacific Aggregates aggregate shipping and storage 
operation at Pier 94 (but not BPA's potential future concrete and asphalt plants); ISG Resources fly ash 
storage facility (in the former grain silos at Pier 90); and Waste Resource Technologies' construction 
materials recycling operation at Pier 70. Not included in this alternative would be the Mission Valley 
Rock asphalt plant, the potential future BPA concrete and asjphalt plants, or Coach USA's bus storage 
and maintenance facility at Pier 96. Under this alternative, concrete production would remain at the 
2003 level through 2015. 

This alternative would also include construction of the Illinois Street Intermodal Bridge, proposed by the 
Port. However, less future development would occur on other Port lands than with the proposed project. 
Alternative B woiild include less of an increase in cargo shipping at Pier 80^nd Piers 94-96, compared to 
the project, and would not include development of the Piers 90-94 backlands. Alternative B would 
include expansion of the Port's dredge material handling site at Pier 94; development of the Pier 70 
mixed-use opportunity area and the Pier 70 maritime reserve area; and development of the Western 
Pacific property. 

This alternative would result in less traffic generation, particularly with Phase II (2015) development, 
than would the project. With this alternative. Phase I daily vehicle trip generation would be about 
20 percent less than with the project (Industry Group vehicle trip generation would be about 30 percent 
less). In 2015, Phase II daily vehicle trip generation would be almost 35 percent less than with the 
project, and peak-hour trip generation, compared to that with the project, would be about 50 percent less 
in the a.m. peak hour and about 85 percent less in the p.m. peak hour. With this alternative's decreased 
traffic volumes, compared to the project, intersection levels of service in 2015 would be improved, 
coiripared to conditions with Phase II project development. In the a.m. peak hour, only two intersections 
would operate at LOS F - Mariposa Street at the southbound 1-280 on-ramp and at the northbound 1-280 
off-ramp. These intersections would also be at LOS F vvith the project. Three other intersections would 
operate at LOS E. Impacts could be mitigated at one of these five intersections. Three other 
intersections that would operate at LOS F with the project would instead operate at LOS D or better with 
Alternative B. In the p.m. peak hour, only three intersections would operate at LOS E or F under 
Alternative B, compared to 1 1 intersections with the project. Impacts at these three intersections could 



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I. SUMMARY 



be mitigated to LOS D or better. Thus, like the proposed project; Alternative B would result in 
significant unavoidable traffic impacts, although the impacts would be less substantial than those with - 
the project. 

Near-term air quality impacts (2003) would be similar to, but slightly less than, those identified for the 
project, because the overall level of activity in Phase I would be similar under this alterriative to that with 
the project. By 2015, the overall emissions of criteria pollutants generated by this alternative would be 
reduced, compared to the project. In particular, annual emissions'of NO^^ from future cargo shipping 
activity at the Port would be about half of those with the project, because the annual volume of cargo 
handled would be about half that with the project. However, criteria pollutant emissions would not be 
reduced to a less-than-significant level, and would be significant, as with the project. Local air quality 
impatts (concentrations of carbon monoxide, respirable particulate matter, and diesel particulate) would 
be less-than-significant, as with the project, and would be would be incrementally less substantial. 
Cumulative air quality effects would remain significant, although this alternative's. contribution would be 
less than that of the project. 

Effects related to hydrology and to hazardous materials would be similar to impacts of the project 
because, while Alternative B would have a reduced level of concrete production and reduced cargo 
shipping, compared to the project, this alternative would include development on virtually all of the same 
sites as would the project, with the only exception being the Pier 90-94 backlands.' With regard to 
hydrology, therefore, this alternative would result in a reduction of about 38 percent in new stormwater 
runoff, compared to the project (and an increase of 18 percent compared to existing conditions), and the 
impact would be less-than-significant with mitigation, as with the project. Concerning hazardous 
materials, because Alternative B would not include development on the Pier 90-94 backlands, there 
would be no effects related to development on the former landfill at Pier 94. Other effects of 
Alternative B with regard to hazardous materials would be less than significant with mitigation, as they 
would with the project. Effects on biological resources would be essentially the same as those of the 
project, and would be less than significant, because this alternative, like the project, would include the 
Illinois Street bridge and associated mitigation. 

Because it would result in less substantial traffic impacts than would the project, and would have slightly 
, less impact on air quality than would the project, the Reduced Density Alternative would be considered 
the Environmentally Superior Alternative. 

ALTERNATIVE C: RESIDENTIAL USE FUTURE SCENARIO 

With regard to Phase I, this alternative would be the same as the proposed project, in that the Industry 
Group project components would be implemented, and the Illinois Street Intermodal Bridge would be 
constructed. However, in Phase II, Alternative C would include residential uses at the Pier 70 Mixed- 
Use Opportunity Area, and would also include less 'office / research and development space there, 
compared to the proposed project. At the Pier 70 Mixed-Use Opportunity Area, this alternative would 



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I. SUMMARY 



include 500 residential units and approximately 200,000 square feet of office / research and development 
use would be included, compared to 610,000 square feet of such uses under the project. Retail space, at 
100,000 square feet, and public access / recreational uses, would be unchanged from the project. Other 
future Port development would be the same as with the project. 

Effects of Alternative C would be generally similar to those of the proposed project. Overall daily 
vehicle trip generation for Phase I and Phase II combined would be about 2.5 pei-cent less than with the 
project, while peak-hour vehicle trips would increase slightly, by about 2.5 percent in the a.m. peak hour 
" and almost 6 percent in the p.m. peak-hour. However, the changes, which would total fewer than 
50 additional vehicles in the a.m. peak hour and just over 100 additional vehicles in the p.m. peak hour, 
would not be substantial enough to result in changes in the 2015 level of service at most intersections. 
For those intersections were level of service would be different, most would improve, compared to the 
project, except at Third Street and Cargo Way, where this alternative would result in LOS E in the p.m. 
peak hour, compared to LOS D with the project. 

Air quality impacts would be incrementally less substantial than those with the project, owing to the 
slight decrease in daily vehicle trip generation. However, regional effects would be significant, as with 
the project, both on a project-specific and cumulative basis. Like the project, this alternative would not 
result in a projfect-specific significant effect on local air quality impacts (concentrations of carbon 
monoxide, respirable particulate matter, and diesel particulate). Also like the project, cumulative local 
air quality effects would be unknown, but would be considered significant with this alternative, and the 
contribution would be similar to that of the project. 

Effects related to hydrology and hazardous materials would be virtually unchanged from those of the 
project, because the areas to be developed and the a.mount of new impervious surface would be the same. 
Because Altemative C would include residential units at the Pier 70 Mixed-Use Opportunity Area, 
remediation of sites where past use of hazardous materials has resulted in contamination would be 
required by law to achieve a higher standard of cleanup. 

Effects oh biological resources would be essentially the same as those of the project, and would be less 
than significant, because this alternative; like the project, would include construction of the Illinois Street 
bridge. Depending on the specific configuration of the development, at the Pier 70 Mixed-Use 
Opportunity Area, site specific noise analysis, and potentially analysis of nighttime lighting, would be 
required to determine whether 24-hour. operations at the Pier 70 shipyard could prove annoying to 
residents at the Mixed-Use Opportunity Area. 



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CHAPTER II 



PROJECT DESCRIPTION 



This SEIR analyzes a series of development proposals - the Industry Group project components - in the 
portion of the Port of San Francisco jurisdiction known as the Southern Waterfront (generally, Pier 70 
south to India Basin). This SEIR also analyzes a Port-sponsored proposal to construct a rail and truck 
bridge across Islais Creek to improve access between the Port's major maritime terminals. Finally, this 
SEIR evaluates, at a lesser level of detail, potential future development on other Port lands in the 
Southern Waterfront to provide a conservative SEIR analysis although there are no such proposed 
projects at this time. Specific locations of the project components analyzed in this SEIR are described 
below in Section C, Project Characteristics and Approvals Required. 

This SEIR will undergo a public comment period as noted on the cover, including a public hearing 
before the Planning Commission on the Draft SEIR. Following the public comment period, responses to 
written and oral comments will be prepared and published in a Draft Summary of Conmients and 
Responses document. The Draft SEIR will be revised as appropriate and, with the Draft Summary of 
Comments and Responses, presented to the Planning Commission for certification as to accuracy, 
objectivity, and completeness. No approvals or permits may be issued before the Final SEIR is certified. 



A. SITE LOCATION 

The Southern Waterfront consists of most of the land and pier area east of Illinois Street between 
Eighteenth Street and Cargo Way, land and pier area north of Cargo Way and east of Third Street, land 
north of Islais Creek and west to Indiana Street and south of Islais Creek and west to approximately 
Quint Street, and land north and south of India Basin, excluding areas outside of Port jurisdiction 
between 21st and 25th Streets and between Cesar Chavez (Army) and Marin Streets (see Figure 1). The 
Southern Waterfront is one of five subareas identified in the Port's Waterfront Land Use Plan, which was 
adopted by the Port Commission in 1997. 



B. PROJECT SPONSORS' OBJECTIVES 

The project sponsors are the Port of San Francisco and several maritime and industrial companies 
(collectively referred to as the "Industry Group"). 



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n. PROJECT DESCRIPTION 



PORT OBJECTIVES 

The Port of San Francisco is trustee for former State-owned lands between Fisherman's Wharf and India 
Basin, including the project area analyzed in this SEIR.^ Pursuant to the Burton Act, the Port's public 
trust responsibilities are to further fisheries, navigation, maritime commerce, natural resource protection 
and recreational facilities for public use. Following an extensive public planning process, in 1997 the 
Port adopted the Waterfront Land Use Plan, defining how the Port will carry out its land use 
responsibilities under the public trust. The Southern Waterfront, one of five waterfront subareas 
identified in the Waterfront Plan, is designated for existing or future expansion of commercial shipping 
and other maritime businesses. The Waterfront Plan also identifies open space areas in the Southern 
Waterfront, and three development opportunity areas where mixed-use commercial and maritime 
development could occur. In addition, the Waterfront Plan allows non-maritime interim uses for land 
designated for future maritime expansion areas. 

In light of the above, the Port's primary objective is to maintain and expand cargo shipping and maritime 
businesses at its existing terminals at Piers 80, 90-92, and 94-96 on the north and south sides of Islais 
Creek east of the existing Third Street Bridge, and the existing ship repair yard at Pier 70. This includes 
increases in shipment of container, breakbulk, dry bulk, liquid bulk, and neo-bulk,^ cargoes, up to an 
equivalent of approximately 250,000 TEU.^ The Port proposes construction of a rail and truck access 
bridge between the two terminals, extending south of Illinois Street, over Islais Creek to increase 
operational efficiencies and marketability of its north and south terminals, to provide direct rail access to 
the terminals, and reduce truck trips that otherwise would occur on city streets. The proposed Illinois 
Street bridge is described further on p. 19. 

Secondary objectives of the Port are to: 

• diversify its marketing efforts to increase utilization of its cargo terminals; 

• maximize the productivity of Port assets through interim use of property reserved for maritime 
expansion; and 

• allow development of non-maritime land uses that would be beneficial to the Port and compatible 
with maritime activities in areas that are surplus to long-term maritime needs. 



Certain sections of this SEIR, such as Transportation and Air Quality, incorporate an area of analysis that extends beyond 
Port land in order to fully capture potential environmental effects. 

Container cargo is shipped in metal containers, which are sealed, reusable metal boxes, generally 20 to 40 feet in length and 
able to hold about 20,000 to 40,000 pounds. Breakbulk (or bulk) cargo refers to loose cargo that is loaded into or unloaded 
from a ship's hold on pallets or in a cargo net. Dry bulk cargo refers to materials loaded via conveyors, spouts, or sccops, 
such as construction aggregates and grains. Liquid bulk refers to cargo carried in tanks, such as petroleum or other oils. 
Neobulk cargo refers to large, non-containerized items such as automobiles, rolls of newsprint, rolls of steel, and the like. 
Twenty-foot-equivalent-units. A TEU is equivalent to the volume of a 20-foot-long cargo container, assumed to be 
24,000 pounds of cargo. 



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n. PROJECT DESCRIPTION 



INDUSTRY GROUP OBJECTIVES 

Members of the Industry Group propose to build facilities primarily for the production, shipping, 
distribution, and recycling of materials used in the construction industry, including concrete, asphalt, fly 
ash, sand, and gravel. Also included is a materials recovery facility^ and a charter bus storage yard and 
service and repair facility. 

One of the primary objectives of the Industry Group is to meet the continuing demand for construction 
materials, including materials required for a series of major projects to be undertaken in and around 
San Francisco over the next several years, such as the reconstruction of the Bay Bridge approach 
between the Bridge and Fifth Street and the buildout of the Mission Bay Redevelopment Areas. 

Other objectives of one or more Industry Group members are to: 

• retain existing operations within San Francisco to allow continuing provision of ready-mix concrete 
in close proximity to sources of demand and avoid potential increased transportation costs if these 
existing operations were unable to remain in the City; 

• similarly, produce asphalt for the San Francisco market, which is now served from outside the City; 

• retain other existing operations in San Francisco that are being displaced by termination of leases;^ 

• facilitate ship-borne import of construction aggregates; 

• co-locate in proximity to one another to achieve maximum efficiency in import, distribution, and 
handling of construction aggregates; 

• retain existing employment and add new employment in San Francisco, and specifically in the 
southeastern part of the City; and 

• operate a construction/demolition material recovery facility in support of the City's goal of meeting 
state requirements to reduce solid waste generation and disposal. 

C. PROJECT CHARACTERISTICS AND APPROVALS REQUIRED 

The "project" analyzed in this SEIR consists of a number of developments in three categories. The first 
consists of a number of proposed uses on Port property that would be implemented via leases with 
private industries (members of the Industry Group); the second category consists of a specific capital 
improvement project proposed by the Port; and the third represents potential long-term future 
development on currently unprogrammed areas of Port property on the Southern Waterfront. 

The development proposed by members of the Industry Group includes a number of construction- 
industry-related and other facilities on Port property, many of which would use cargo shipping as a 
means of transporting materials to and from those facilities. The capital improvement program proposed 
by the Port is construction of a rail and truck bridge across Islais Creek. The future development would 



A materials recovery facility (MRF) separates and processes recyclables from mixed waste and/or separates commingled 
recyclables. 

Of the seven Industry Group members, four must relocate due to impending lease terminations. 



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II. PROJECT DESCRIPnON 



potentially affect the Piers 90-94 backlands. Pier 70, and the Pier 70 Mixed Use Opportunity Area, as 
well as a portion of the former Western Pacific rail yard. Continuation of and growth in commercial 
shipping at the Port's Marine Terminals at Piers 80 and 94-96 is also considered part of the project. Each 
of these project components is discussed below. Because each component would be subject to its own 
approval action(s), a discussion of permits and required approval actions is provided following the 
description of each component. Discretionary approvals that relate to all project components, including 
the EIR certification process, are discussed following the description of the individual components. 



EsTDUSTRY GROUP PROJECTS 

Six private entities have proposed leasing portions of the Port of San Francisco's Southern Waterfront 
area and implementing development proposals, primarily related to the construction industry, and these 
project components make up the first category within the project description.^'^ Each of these project 
components would involve a project sponsor leasing property from the Port and making improvements 
on the leased site. In most cases, the lease would involve unimproved land that the sponsor would 
develop. In some cases, the individual sponsors would occupy one or more existing buildings on Port 
property with lease provisions for tenant-financed improvements to such buildings. 

Characteristics of the Industry Group project components are summarized in Table 1 , p. 6. The locations 
of these individual components are shown in Figure 2, p. 8. 

All of the Industry Group project components would be developed on Port property. Because of 
conditions imposed upon the Port by the State of California when the state granted the Port title to its 
lands, land uses on Port property must generally be consistent with what is known as the "public trust 
doctrine." This requirement normally limits use of Port lands to commerce, navigation and fisheries, 
although short-term leases are permitted to lessees engaged in non-trust uses. While two of the Industry 
Group members would have no maritime activity, and while the lease terms of the proposed uses would 
vary, for purposes of a conservative analysis of future conditions, this EIR assumes that all uses analyzed 
herein will continue to at least the cumulative horizon year of 2015, a time frame that is consistent with 
other recently prepared environmental review documents in San Francisco. 

As noted, several of the Industry Group project components are designed to respond to anticipated 
demand for construction materials. Estimates of such demand, developed by the project sponsors, 
provide the basis for the magnitude of facilities and operations that would result from these project 
components. These market projections are discussed in Appendix A. 



Although the Port is negotiating with six potential Industry Group tenants, and this SEIR describes the Industry Group as 
having six components, one of the components would involve a joint lease with two operators. Bode Grave! and Mission 
Valley Rock (see Table 1, p. 6). Therefore, there are seven operators involved in the Industry Group. 



Case No. 1999.377E 



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Southern Waterfront SEIR 



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n. PROJECT DESCRIPTION 



BODE GRA VEL I MISSION VALLEY ROCK 

This component of the project would consist of two adjacent facilities to be developed at Pier 92. Bode 
Gravel Company would develop a ready-mix concrete plant and Mission Valley Rock Company would 
develop a marine terminal to import aggregate materials (gravel and crushed rock) for use in production 
of concrete. In addition, Mission Valley Rock is pursuing discussions with the Port to develop an asphalt 
plant, which would also use imported aggregate materials. Although the Port has not indicated any 
affirmative interest in development of an asphalt plant, the potential impacts of such an operation are 
included in this EIR analysis. The two operators are discussed together because the current proposal 
calls for Bode Gravel and Mission Valley Rock to be joint tenants of the Port. However, ownership and 
operations of the two facilities would be separate. 

Bode Ready-Mix Concrete Plant 

Bode currently operates a ready-mix concrete^^ plant at Third and Sixteenth Streets, within the Mission 
Bay area now under development. Under the project. Bode would construct an all-new facility at Pier 
92, and the existing plant would be dismantled. The capacity of the new plant would be comparable to 
that of the existing plant, and Bode has applied to the Bay Area Air Quality Management District for a 
permit that would allow the same maximum annual production as is currently permitted (production 
volume of 500,000 cubic yards (1,000,000 tons) per year, which is greater than the existing plant's 
highest-volume year, 317,400 cubic yards in 1998). The Bode plant is assumed to produce about 
325,000 cubic yards of concrete in the immediate future, increasing to about 425,000 cubic yards by 
2015 (see assumptions in Appendix A). 

The new Bode ready-mix plant would be at the east end of Amador Street, approximately one-third mile 
east of Third Street. It would be situated between an existing Mission Valley Rock sand processing plant 
to the north (on the Pier 92 wharf) and a rendering plant operated by Darling International to the south. 
The ready-mix plant would occupy approximately 3 acres (about 130,000 square feet) of land that is 
currently undeveloped, with the exception of several railroad spurs. All but one of the tracks would be 
removed, and the entire site would be paved with asphalt or concrete. The remaining track would be 
rehabilitated to provide rail access to the concrete plant. 

The ready-mix plant would include receiving facilities for aggregate material (gravel) delivered by 
bottom-hopper dump trucks and facilities for receiving ship-bome aggregate by conveyor from the 
adjacent Mission Valley import facility; storage bins for aggregate and sand; storage silos for Portland 



Concrete consists of sand, aggregate (gravel), water, Portland cement and fly ash (a byproduct of coal combustion), and a 
limited volume of additives that control setting time and flow rate, and sometimes add color. 



Case No. 1999.377E 



9 

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Southern Waterfront SEIR 



n. PROJECT DESCRIPTION 



cement and "fly ash,"'^ both of which are used in the production of concrete; two mixers; and a series of 
conveyance systems for movement of the materials throughout the plant - conveyor belts for the solid 
aggregate material and an enclosed pneumatic pumping system for the Portland cement and fly ash, with 
so-called "baghouse filters" for dust control. Bode would also use water spray bars to reduce dust from 
aggregates in outdoor storage piles. Each of the two combined mixers and storage silos, known as a 
"batching plant," would be approximately 65 feet tall. In addition to the production facilities, the 
operation would have a truck maintenance shop, truck washout station with water reclamation, an office 
trailer, and parking for concrete-mixer trucks and employee vehicles. 

Most of the sand for concrete production would come from Mission Valley Rock's sand processing plant 
that currently operates at Pier 92, and which processes and cleans sand dredged from San Francisco Bay. 
Additional sand would be delivered by truck from the East Bay or delivered by cargo ship or barge. 
Aggregate could be delivered by truck from the East Bay or received by ship - potentially through 
Mission Valley Rock's marine terminal - while cement would come by rail and truck from the South 
Bay. 

Waste concrete left from unused production and undelivered loads would be processed to remove 
aggregate for reuse in production of additional concrete, to the extent feasible. Other waste would be 
delivered to a construction debris recycler for processing. 

The ready-mix plant would employ about 20 persons on-site. Bode projects that the plant would 
generally operate from 6:00 a.m. to 5:00 p.m., Monday through Saturday, with occasional Sunday and 
nighttime operations to serve major jobs.'* These hours would be the same as at Bode's existing Third 
Street plant. 

Aggregate, sand, and cement would be delivered to the plant in semi-trailer trucks and by conveyor from 
Mission Valley Rock, and ready-mix trucks ("cement mixers") would make deliveries of concrete to 
customers and construction locations primarily within San Francisco. Trucks would travel on Amador 
Street to Third Street, and those trucks traveling outside San Francisco would generally use Cesar 
Chavez (Army) Street to reach the U.S. 101 or Interstate 280 freeways. 

Bode anticipates that the new ready-mix plant would be operational in 2001. 



Fly ash is a powdery material, composed largely of silica, that is captured from the exhaust gas of coal-fired power plants. It 
reacts chemically with the calcium hydroxide in Portland cement and itself becomes cementitious (that is, helps bind the sand 
and aggregate in the concrete). Ry ash is advocated as improving the strength and durability of concrete - although it slows 
the initial curing - while at the same time reducing the relative volume of cement needed and thereby reducing the energy 
use and combustion byproducts of cement production. Fly ash is mandated in concrete by both Caltrans, for its projects, and 
by the U.S. EPA, for federal projects. One of the Industry Group components would include a fly ash import operation (see 
ISG Resources, p. 14). 

Certain concrete foundations for large buildings not supported on piles or piers must be poured continuously for 
24 consecutive hours or more to allow the concrete to cure properly. 



Case No. 1999.377 E 



10 

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Southern Waterfront SEIR 



II. PROJECT DESCRIPTION 



Mission Valley Rock Aggregate Import Terminal and Asphalt Plant 

The Mission Valley Rock aggregate import terminal would be located immediately west of the Bode 
concrete plant, also on Amador Street, approximately one-quarter mile east of Third Street. As indicated 
previously. Mission Valley Rock is also pursuing discussions with the Port to develop an asphalt^^ plant. 
Together, the facilities would occupy about 5.2 acres (about 225,000 square feet). There are currently no 
privately owned commercial asphalt plants in San Francisco (the closest is in Brisbane). The City 
operates a plant on Jerrold Avenue for street repairs within San Francisco. Mission Valley Rock 
currently has a sand dredging and processing operation at Pier 92, east of the proposed Bode concrete 
plant, where operations would continue as at present.'^ 

To provide a conservative analysis, this SEIR assumes that the asphalt plant would be developed. The 
proposed asphalt plant would include receiving facilities for aggregate material (gravel); storage bins for 
aggregate and sand; storage tanks for asphalt cement; an asphalt oil heater and an asphalt drum 
dryer/mixer, both gas-fired; storage bins for the finished asphalt product, which would be dispensed from 
the bins into trucks for delivery to the job site; and conveyors for movement of the materials throughout 
the plant. The dryer/mixer would be equipped with a baghouse filter for dust control. In addition to the 
production facilities, the plant would have an office/control room, a small tool trailer, and employee 
vehicle parking. 

The aggregate terminal would include conveyor systems for transferring aggregate from ships to indoor 
and outdoor storage piles and for transferring aggregate from storage to the proposed asphalt plant and to 
the Bode ready-mix concrete plant, as well as both indoor (in an existing warehouse along the Islais 
Creek waterfront ) and outdoor storage facilities. Mission Valley Rock would use spray bars to sprinkle 
aggregates with water during ship unloading, both at the ship conveyor and at the outdoor stockpile 
where the material would arrive. The entire Mission Valley Rock site would be paved with asphalt or 
concrete. 

Most of the sand for asphalt production would come from Mission Valley Rock's existing sand 
processing plant at Pier 92. Aggregate would be delivered by ship and barge at the adjacent import 
terminal on Islais Creek, while asphalt cement would come by truck from refineries in Contra Costa or 
Solano counties. 

The asphalt plant and aggregate terminal would employ about 10 persons on-site. The facilities would 
generally operate from 6:00 a.m. to 4:00 p.m., Monday through Saturday, with occasional Sunday and 
nighttime operations to serve major paving jobs. Plant capacity would be 400 tons per hour, with limits 
of 6,000 tons per day for 60 days per year and 4,000 tons per day otherwise. Total asphalt production 
would be 400,000 tons per year in the near term, increasing to about 550,000 tons by 2015 (see 



Asphalt consists of primarily of aggregate (crushed rock) and asphalt cement, a petroleum product, with a small amount of 
sand. 

The sand plant cleans and dries sand that is dredged from San Francisco Bay for use in concrete production. At present, this 
sand is trucked to existing Bode and RMC Pacific ready-mix plants on Third Street in the Mission Bay area. 



Case No. 1999.377E 



11 

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Southern Waterfront SEIR 



II. PROJECT DESCRIPTION 



assumptions in Appendix A). While barge and ship calls would be periodic, the marine terminal would 
be used daily for aggregate storage and shipment to the asphalt plant and to other facilities, including the 
Bode ready-mix plant. Ship and barge calls would occur perhaps once a month in the first year of 
operation, and as often as twice per month by 2015 as the volume of aggregate received by ship increases 
over time. The import terminal could handle up to 1.2 million tons of aggregate per year. 

Assuming operation of the asphalt plant, finished asphalt would be delivered to customers and 
construction locations both within and outside San Francisco, with out-of-city deliveries generally 
limited to the northern Peninsula. Trucks would travel on Amador Street to Third Street, and those 
trucks traveling outside San Francisco would generally use Cesar Chavez (Army) Street to reach the 
U.S. 101 or Interstate 280 freeways. 

Mission Valley Rock Company anticipates that the asphalt plant and aggregate terminal would be 
operational in 2001. 

Zoning and Approvals Required 

The Bode and Mission Valley Rock sites are in a M-2 (Heavy Industrial) Use District and a 40-X Height 
and Bulk District. These projects would be consistent with the M-2 Use District and the 40-X Height 
and Bulk District.'^ These project components could not proceed unless the Port Commission approves 
a lease agreement authorizing the proposed uses. Any non-maritime lease agreement would also require 
approval by the Board of Supervisors if it would exceed $1 million in revenue to the Port or would be for 
a term of 10 years or longer; however, the Bode-Mission Valley facility would include a maritime 
component. Each project component would require an Authority to Construct and a Permit to Operate 
from the Bay Area Air Quality Management District. Bode has an existing Permit for its Third Street 
facility that would be amended for the new Pier 92 ready-mix plant. Both facilities would require a 
General Storm Water Permit from the Regional Water Quality Control Board, and each would be 
required to prepare a Storm Water Pollution Prevention Plan to address collection, monitoring, and 
discharge of runoff. Each plant would also require a Hazardous Material Storage Permit from 
San Francisco Fire Department for an on-site fuel tank for the front-end loaders that would move 
materials within the plants, and might also require an industrial sewer discharge permit from the City 
Public Utilities Commission if any process water is to be discharged into the City sewer system. The 
project would also require building permit(s) from the Port. Neither facility would be constructed within 
the 100-foot shoreline band. However, the Mission Valley Rock facility could require BCDC approval 
for a change in use in the existing warehouse, which is currently used for storage. 



Pursuant to Planning Code Section 260(b)(2)(M), "structures and equipment necessary for the operation of industrial plants," 
such as the 65-foot-tall concrete batching plant, are exempt from the applicable height limit as long as they do not contain 
separate floors. 



Case No. 1999.377E 



12 

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Southern Waterfront SEIR 



n. PROJECT DESCRIPTION 



BRITISH PACIFIC AGGREGATES 

British Pacific Aggregates (BPA) would develop a storage facility for the waterbome importation of 
construction aggregates (sand, gravel, and crushed stone) to be used in the production of concrete and 
asphalt. BPA proposes to use Pier 94 as the dock for ships that would bring aggregate from out-of-state 
to supplement and/or replace existing local supplies. The aggregate would be delivered by self- 
unloading ships directly to Pier 94, where it would be unloaded using on-board equipment and stored in 
stockpiles in up to about six acres on the pier apron, approximately 350 feet shoreward of the wharf. To 
minimize dust, BPA would use spray bars to moisten aggregate both during unloading and while in 
storage. BPA proposes to supply local producers of ready-mix concrete and asphalt, potentially 
including Bode Gravel Company's ready-mix plant and Mission Valley Rock Company's proposed 
asphalt plant (see above), and RMC Pacific's ready-mix plant concrete (see below, p. 15), as well as 
other existing, smaller concrete producers in the project area'^ and possibly elsewhere. 

Improvements to be constructed would include conveyors to move material from ships to stockpiles and 
from one location to another and/or for loading into trucks for transport to end users. Front-end loader(s) 
may also be used for loading trucks. As noted above, spray bars would be employed to keep the material 
moistened while in storage, to minimize dust. No new paving would be needed, because the BPA 
storage facilities would be located on an already-paved portion of the Pier 94 apron. 

In addition to the shipping and storage facilities, BPA has indicated that it may develop a ready-mix 
concrete plant and/or an asphalt plant inland from the stockpile area. Both of these uses are under 
discussion with the Port and have been included in this SEIR for purposes of a conservative analysis. 
These facilities, if constructed, would use aggregate material taken directly from the stockpiles (without 
the need to employ diesel haul trucks). Production of ready-mix concrete and/or asphalt by BPA would 
be contingent on the company capturing a share of the local market for one or both products. As 
described in Appendix A, this SEIR does not assume that BPA would engage in production of either 
product. However, as also stated in Appendix A, the net result of BPA producing either or both of these 
materials would not be an increase in the total volume of concrete or asphalt manufactured within the 
Southern Waterfront area, but an incremental shift in the location of such production. Should such 
production be undertaken, the concrete and/or asphalt plant(s) would be portable facilities that would be 
erected on a semi-permanent basis at Pier 94 for the duration of BPA's lease. Regardless of whether 
concrete or asphalt were produced, no permanent structures would be erected. Other facilities, such as an 
office and tool/repair shop, would be within portable trailers. On-site parking for up to about 
15 employees would be provided. The total site area would be about 10 acres, of which six acres would 
be used for aggregate stockpiling. 



Existing ready-mix concrete producers are located on Amador Street (Pier 90) and at the former Western Pacific rail yard 
adjacent to Pier 80. 



Case No. 1999.377E 



13 

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Southern Waterfront SEIR 



n. PROJECT DESCRIPTION 



Road access would be via Cargo Way and Third Street, with Cesar Chavez (Army) Street and U.S. 
Highway 101 and Interstate 280 the anticipated routes to and from most non-local destinations. 

The BPA facility would be operational late in 2001. 
Zoning and Approvals Required 

The BPA site is in a M-2 (Heavy Industrial) Use District and a 40-X Height and Bulk District, and would 
be consistent with these regulations; the batching plant would be exempt from the 40-foot height limit 
pursuant to Planning Code Section 260(b)(2)(M). The BPA project component could not proceed unless 
the Port Commission approves a lease agreement authorizing the proposed uses. Any non-maritime 
lease agreement would also require approval by the Board of Supervisors if it would exceed $1 million in 
revenue to the Port or would be for a term of 10 years or longer; however, the BPA operation would be a 
maritime facility. Because the BPA project component would not include storage of aggregate within 
100 feet of the shoreline, no BCDC approval would be required. (On-ship conveyors would preclude the 
need for construction of any facilities within the 100 feet of the shoreline.) The BPA facility would 
require an Authority to Construct and a Permit to Operate from the Bay Area Air Quality Management 
District; a General Storm Water Permit from the Regional Water Quality Control Board, with the 
required Storm Water Pollution Prevention Plan; and, potentially, a Hazardous Material Storage Permit 
from San Francisco Fire Department if an on-site fuel tank is required. This component would require an 
industrial sewer discharge permit from the City Public Utilities Commission and building pennit(s) from 
the Port. 



ISG RESOURCES 

ISG Resources Inc. proposes to re-use two existing banks of now- vacant former grain silos at Pier 90 for 
the storage of "fly ash," a byproduct of coal-fired power plants that is used as a partial replacement for 
Portland cement in the production of concrete. The silos formerly stored grain that was brought in by 
rail and then loaded from the silos onto ships for export. These operations were discontinued following 
the 1989 Loma Prieta earthquake.'^ Fly ash would be brought in by rail car, transferred to the silos, and 
then made available to concrete producers, including those currently proposing to operate in the 
immediate vicinity - Bode, RMC Pacific, and smaller local producers (and potentially British Pacific). 
In the future, fly ash could be brought by barge from other locations and offloaded into the silos. 
Outbound shipments to concrete batching plants would be in trucks with pneumatic pumping systems. 

Physical improvements to be undertaken would consist of rehabilitation of the silos; enclosure of the 
conveyor system and installation of state-of-the-art dust control systems on the silos and conveyor 
system; replacement of the electrical and propulsion components for the conveyor system; construction 



ISG recently rehabilitated older silos for fly ash storage and distribution in Pomona, California, and also has fly ash 
operations in Redwood City, Sacramento, San Bernardino, and Oxnard. 



Case No. 1999.377E 



14 

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Southern Waterfront SEIR 



n. PROJECT DESCRIPTION 



of a truck loading facility; and rehabilitation of at least one of the existing rail spurs to allow for 
shipment of fly ash to the ISG site by rail car. 

ISG proposes to undertake this project component in two phases, each corresponding with one of the two 
banks of silos. Phase I would renovate the newer bank of silos, and would involve approximately 
70,000 square feet of site area. Phase II would involve renovation of the older silos, which are 
anticipated to require greater time and effort, and would occupy about 30,000 square feet. The combined 
site area would be about 2.3 acres on the north side of Amador Street, west the proposed Mission Valley 
Rock site and approximately 800 feet east of Third Street. 

ISG estimates employment at the fly ash facility at between eight and 30 persons, depending on demand 
for the fly ash. Employee parking would be provided on-site. Non-local trucks would travel on Amador 
Street to Third Street. 

The company anticipates scaling up to an ultimate volume, by 2015, of 100,000 tons of fly ash handled 
per year, about half of which could be used by other Industry Group firms (Bode and RMC Pacific). ISG 
estimates that the rehabilitation of the former grain silos and other equipment would take about five 
months. The fly ash facility could be operational in 2001. 

Zoning and Approvals Required 

The ISG Resources site is in a M-2 (Heavy Industrial) Use District and a 40-X Height and Bulk District. 
The operation would use the existing former grain silos. Although the silos are taller than 40 feet, only 
minor changes would be required to the exterior (primarily associated with dust control equipment), and 
this project component therefore would be consistent with the use and height and bulk controls for the 
site. The ISG project component could not proceed unless the Port Commission approves a lease 
agreement authorizing the proposed uses. Any non-maritime lease agreement would also require 
approval by the Board of Supervisors if it would exceed $ 1 million in revenue to the Port or would be for 
a term of 10 years or longer. The project would not require BCDC approval, as it would not be within 
100 feet of the shoreline. The ISG component would require an Authority to Construct and a Permit to 
Operate from the Bay Area Air Quality Management District; a General Storm Water Permit from the 
Regional Water Quality Control Board, with the required Storm Water Pollution Prevention Plan; and, 
potentially, a Hazardous Material Storage Permit from San Francisco Fire Department if an on-site fuel 
tank is required. This component would also require an industrial sewer discharge permit from the City 
Public Utilities Commission and building permit(s) from the Port. 



RMC PACIFIC MATERIALS 

RMC Pacific proposes to construct a ready-mix concrete plant on a 3.1-acre parcel at the west end of 
Pier 80, at the southeast comer of Illinois and Marin Streets, to replace its existing ready-mix plant at 
Third and Mariposa Streets, within the Mission Bay project currently under development. RMC's 
existing plant would be dismantled, and the new plant would be developed with new equipment. 



Case No. 1999.377E 



15 

ESA 990267 



Southern Waterfront SEIR 



II. PROJECT DESCRIPTION 



The RMC Pacific site is currently paved and in use as a storage yard by Marine Terminals Corporation, 
which operates the Port's North Container Terminal at Pier 80. Because of the site location, RMC 
proposes ultimately to receive approximately 60 percent (by weight) of its raw materials - primarily 
aggregate - by rail and ship.^o The firm currently receives all supplies by truck. The proposed new 
ready-mix plant would include receiving and unloading facilities to accommodate both rail cars and 
ships; storage bins for aggregate and sand; a 65-foot-tall batching plant with cement and fly ash storage 
silos, mixer, office, and dust containment system; and a series of conveyors for movement of the 
materials throughout the plant. In addition to the production facilities, the ready-mix plant would have a 
truck maintenance shop (involving remodeling of an existing open-bay structure), truck washout station 
with water reclamation, and parking for concrete-mixer trucks and employee vehicles. 

Waste concrete left from unused production and undelivered loads would be processed to remove 
aggregate and clarified water for reuse in production of additional concrete, as possible. Other waste 
would be delivered to a construction debris processor for recycling. 

The RMC facility would generally operate from 7:00 a.m. to 3:00 p.m., Monday through Friday, with 
occasional nighttime operations to serve major jobs; these hours would be the same as at RMC Pacific's 
existing Third Street plant. Approximately 30 persons would be employed on a full-time basis, the same 
number as at the existing facility. The RMC plant is assumed to produce about 325,000 cubic yards of 
concrete in the immediate future, increasing to about 425,000 cubic yards by 2015 (see assumptions in 
Appendix A). 

Concrete deliveries would use Third Street to reach points north and Third Street or Bayshore Boulevard 
to points south, in San Francisco. Truck traffic to or from points outside the City would use 
U.S. Highway 101 and Interstate 280 to the Cesar Chavez (Army) Street exit. No on-site truck fueling 
would be provided. RMC mixers would use off-site commercial fueling stations. 

The RMC Pacific plant would be operational in 2001. The existing Third Street plant would remain 
operational as a satellite facility, at about half of its capacity, for approximately two years as the new 
plant scales up production. 

Zoning and Approvals Required 

The RMC Pacific site is in a M-2 (Heavy Industrial) Use District and a 40-X Height and Bulk District, 

and would be consistent with these regulations; the batching plant would be exempt from the 40-foot 

height limit pursuant to Planning Code Section 260(b)(2)(M). The RMC Pacific project component 

could not proceed unless the Port Commission approves a lease agreement authorizing the proposed uses. 

Any non-maritime lease agreement would also require approval by the Board of Supervisors if it would 

exceed $1 million in revenue to the Port or would be for a term of 10 years or longer; however, the RMC 

facility would include a maritime component. As this project component would be developed partially 
• * 

The transportation analysis for this SEIR assumes approximately 40 percent of RMC's raw materials would come by ship 
and rail in the near term, increasing to about 60 percent by 2015. 



Case No. 1999.377 E 



16 

ESA 990267 



Southern Waterfront SEIR 



n. PROJECT DESCRIPTION 



within 100 feet of tlie shoreline, it would require approval from BCDC. The RMC Pacific component 
also would require an Authority to Construct and a Permit to Operate from the Bay Area Air Quality 
Management District and a General Storm Water Permit from the Regional Water Quality Control 
Board, with the required Storm Water Pollution Prevention Plan. The City would also have to issue an 
industrial sewer discharge permit from the City Public Utilities Commission and building permit(s) from 
the Port. 



WASTE MANAGEMENT 

Waste Resources Technologies (WRT), a subsidiary of Waste Management Inc., proposes to operate a 
Construction/Demolition Material Recovery Facility (MRF) in an existing building at Pier 70, in the 
northern portion of the project site. The MRF, which would reclaim usable materials, such as metal and 
wood, contained in construction and demolition debris for recycling, would replace a former WRT 
facility near 3Com Park, which was closed in 1999. 

WRT proposes to lease an existing building at Pier 70, located near 20th and Illinois Streets, in the 
former Union Iron Works complex. The structure, identified as Building 6, contains approximately 
35,000 square feet of interior space. There would be no structural modifications to the exterior of the 
building, which was constructed in 1941. However, WRT would renovate portions of the building's 
interior to accommodate the MRF. WRT would install a sort line with associated screens, conveyors, 
and other equipment for processing of construction and demolition material inside Building 6. In 
contrast to WRT's former outdoor facility at Candlestick Point, all sorting and storage of material would 
be accomplished within Building 6. Parking would be provided on-site for employee vehicles and for 
staging of semi-trailer transfer trucks. 

WRT anticipates 30 on-site employees working two shifts (day and swing), with the facility to operate 
16 hours per day, six days per week. An estimated 350 tons per day of construction and demolition 
waste would be processed. Inbound material would be delivered primarily in debris-box-sized loads, 
while outbound trips would be made using semi-trailer trucks. 

Site access would be via 20th and Third Streets. Inbound trucks would come from various construction 
sites. Outbound trucks would be destined for local processors in the case of recyclable materials and 
local landfills, such as Redwood Landfill in Marin County and Altamont Landfill in Alameda County, in 
the case of materials that cannot be reused. Although no waterbome transport of materials is currently 
planned, there is a potential that recyclable materials, such as paper and metals, could be shipped to 
processors through the Port in the future. 

It is expected that the WRT facility would be in operation by 2001. 



Case No. 1999.377E 



17 

ESA 990267 



Southern Waterfront SEIR 



II. PROJECT DESCRIPTION 



Zoning and Approvals Required 

The Waste Management site is in a M-2 (Heavy Industrial) Use District and a 40-X Height and Bulk 
District. Although the existing Building 6 is taller than 40 feet, the project proposes no changes to the 
structure's height or massing and it would therefore be consistent with the height and bulk limits for the 
site. The Waste Management project component could not proceed unless the Port Commission 
approves a lease agreement authorizing the proposed uses. Any non-maritime lease agreement would 
also require approval by the Board of Supervisors if it would exceed $1 million in revenue to the Port or 
would be for a term of 10 years or longer. As a solid waste facility, this project component would 
require conditional use authorization from the San Francisco Planning Commission. In addition, the 
WRT component would require issuance of a Solid Waste Facility Permit, which must be approved by 
the Califomia Integrated Waste Management Board and the San Francisco Department of Public Health, 
as the Local Enforcement Agency. This project component would require a modification of the County 
Integrated Waste Management Plan. The project would also require an Authority to Construct and a 
Permit to Operate the on-site processing equipment from the Bay Area Air Quality Management District. 
The project would also require building permit(s) from the Port. The project would require BCDC 
approval, as it would be within 100 feet of the shoreline. 

COACH USA 

Coach USA proposes to lease approximately 8 acres at Pier 96 for bus storage, maintenance and repair, 
and ancillary office space. Coach USA, through its subsidiary Grosvenor Bus Lines Inc., currently 
operates Gray Line tour buses, as well as charter bus service, and transit and paratransit service for 
transit agencies including Golden Gate Transit and San Mateo County Transit (SamTrans). Grosvenor 
Bus Lines currently operates from a facility at Eighth and Harrison Streets. The company would relocate 
to Pier 96 and vacate its existing Eighth Street operations, where its lease is not being renewed. 

This project component would include use of an existing paved storage yard of approximately 6.9 acres 
(about 300,000 square feet), and use of existing buildings for bus maintenance and repair building (about 
26,000 square feet), office space (about 11,500 square feet), and additional miscellaneous building space 
(about 4,000 square feet). Coach USA plans to construct a fuel island and diesel fuel storage tank and a 
bus washer. The company also proposes to make some improvements to the buildings that would be 
used for maintenance/repair and office space. Anticipated on-site employment would be approximately 
200. 

On-site parking for employees and buses would be provided. Buses would enter and leave Pier 96 via 
Cargo Way. 

Zoning and Approvals Required 

The Coach USA site is in a M-2 (Heavy Industrial] Use District and a 40-X Height and Bulk District. 
The project would comply with the zoning and height and bulk requirements for the site. This project 
component could not proceed unless the Port Commission approves a lease agreement authorizing the 



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proposed uses. Any non-maritime lease agreement would also require approval by the Board of 
Supervisors if it would exceed $1 million in revenue to the Port or would be for a term of 10 years or 
longer. The Coach USA project would require a Hazardous Material Storage Permit from the 
San Francisco Fire Department for operation of a fuel storage tank and an industrial sewer discharge 
permit from the City Public Utilities Commission, and would have to file a Business Plan for storage of 
any hazardous materials. Because of the outdoor storage yard, this component could also require a 
General Storm Water Permit from the Regional Water Quality Control Board, with the required Storm 
Water Pollution Prevention Plan. The project would also require building permit(s) from the Port. The 
project would not require BCDC approval, as it would not be within 100 feet of the shoreline. 

ILLINOIS STREET INTERMODAL BRIDGE 

As the second category of components in the SEIR project description, the Port of San Francisco 
proposes to construct a bridge across the Islais Creek channel one block east of the existing Levon 
Hagoop Nishkian drawbridge on Third Street. The new bridge would extend across the channel along 
the line of Illinois Street, connecting the Port's North Container Terminal at Pier 80, on the north side of 
Islais Creek, with the numerous Port facilities on the south side of Islais Creek. These facilities include 
the Port's South Container Terminal at Piers 94-96; the adjacent Intermodal Container Transfer Facility 
(the "ICTF," where cargo containers are transferred directly from ship to rail and vice versa); Piers 90 
and 92 along the south side of Islais Creek channel; and the Piers 90-94 backlands area. The proposed 
bridge location is shown on Figure 2, p. 8. 

The Illinois Street bridge would provide a more direct route for rail cargo to and from Pier 80. Rail 
traffic destined to Pier 80 must currently travel north on a route that generally follows Interstate 280, 
more than one mile past the project site and through the Mission Bay area, beyond 16th Street, before 
returning south along Illinois Street to Pier 80. As part of the approved Mission Bay project, a portion of 
the existing rails through the Mission Bay area will be removed and are proposed for replacement with 
new rails within 16th Street, and a new switchback within a planned waterfront open space on the Terry 
Francois Boulevard right-of-way unless or until the Illinois Street Bridge is constructed. 

The new bridge would provide a direct rail link between the Port's two container terminals, eliminating 
the need for the existing and future routes through Mission Bay. At present, rail cars that are moved 
between Pier 80 and Piers 94-96 must travel the same route described above, north to 16th Street before 
returning south to Piers 94-96 via a rail link that diverges from the main line near Jerrold Avenue and 
Rankin Street. This so-called Quint Street Rail Link currently permits direct access from the main Union 
Pacific line (to and from points south of San Francisco) to Piers 94-96 and the ICTF, and would connect 
to Pier 80 via the Illinois Street bridge. Although rail traffic to Pier 80 and between the two terminals is 
limited at present, it is expected to increase in the future. The bridge would reduce the existing 
approximately four-mile rail trip between Pier 80 and Piers 94-96, over the existing rail route, to a direct 
route of approximately 0.2 miles. When the bridge is completed, the rails that run near 16th Street would 



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be removed, and there would be no need to install new rails in 16th Street or in the new waterfront open 
space.2' The existing and proposed rail routes are shown on Figure 3. 

The Illinois Street bridge would be approximately 28 feet wide and would have a single rail line in the 
center and two traffic lanes, one in each direction, that would overlap the rails. Thus, the bridge would 
provide a direct truck connection between the two container facilities, with trucks having access to the 
bridge only when no trains were crossing. (No sidewalks are proposed. However, bicycle access would 
be allowed in the traffic lanes when no trains are crossing.) 

As proposed, the bridge project does not include a roadway that links the east end of Amador Street with 
Piers 94-96. Therefore, the truck route between Pier 80 and Piers 94-96 would be: south on Illinois 
Street and across the bridge to Amador Street, west on Amador to Cargo Way, and southeast on Cargo 
Way to Piers 94-96. 

The Port currently estimates the cost of the Illinois Street bridge at approximately $10 million. The Port 
was awarded a $4 million State Transportation Improvement Program (STIP) grant and has applied for 
an additional $500,000 in STIP funds. Catellus Corporation, the developer of Mission Bay, would also 
provide some of the funding, as would the Port. Construction of the bridge is anticipated in 2003. As 
part of the bridge component of the project, the Port would install a system of stand pipes along Islais 
Creek for fire protection purposes. This system would allow fire engines to draw water directly from 
Islais Creek via hydrants placed at the water's edge, just as under existing conditions along the 
Embarcadero. In addition, the Port would provide pumping equipment, and the Fire Department is 
considering upgrading its high-pressure Auxiliary Water Supply System in the vicinity of Islais Creek 
west of Third Street. 

The Port proposes that the Illinois Street bridge be a "Lift-Segment Movable Bridge," meaning that the 
center span, which would be 60 feet long, would be constructed as three individual segments that could 
not be mechanically raised in place like a drawbridge. Instead, each of these segments could be lifted by 
a crane and stored on concrete piers that would be built next to the bridge. Unlike a drawbridge, a lift- 
segment bridge is designed to be opened only infrequently, primarily for passage of maintenance vessels 
and barges. Therefore, the new bridge would probably be opened no more than once yearly. 

The proposed lift-segment bridge would have the same clearance above water as the Third Street 
drawbridge over Islais Creek, which is a minimum of 4 feet of clearance at mean higher high water 



Rails in Illinois Street south of the Mission Bay project area are not currently planned for removal. 



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w 



China Basin 




: — — — — — J999.377E: Southern Waterfront SEIR (ESA 990267) m 

SOURCE: Environmental Science Associates. 

Figure 3 

Existing and Proposed 
Freight Rail Routes 



21 



n. PROJECT DESCRIPTION 



level.22 This would permit navigation beneath the Illinois Street bridge by small pleasure craft such as 
canoes, kayaks, and other small vessels like rowboats. The Port believes the navigational needs of the 
west end of Islais Creek are and will continue to be for small vessels. A hand-launch dock has been 
constructed on the south shore of Islais Creek, just west of the existing Third Street drawbridge. A sand 
ramp has also recently been constructed to facilitate the hand-launching of small vessels. The Port does 
not propose to open the new Illinois Street bridge to permit the passage of larger pleasure craft or 
sailboats. 



APPROVALS REQUIRED 

The design and construction of the Illinois Street bridge would be subject to approval of a bridge permit 
by the U.S. Coast Guard, which must determine the future navigational needs of Islais Creek before it 
issues a permit. The Coast Guard would determine whether a lift-segment span is appropriate. The 
bridge would also require approval by the Bay Conservation and Development Commission (BCDC) 
because it would be constructed over the Bay and within the 100-foot band along the San Francisco Bay 
shoreline over which BCDC has jurisdiction. The BCDC would also be required to fmd that the 
proposed bridge, as a federal action (i.e., approval by the U.S. Coast Guard) is consistent with the federal 
Coastal Zone Management Act. Approval could also be required from the U.S. Army Corps of 
Engineers under Section 404 of the federal Clean Water Act (including consultation with the U.S. Fish 
and Wildlife Service) and Section 10 of the federal Rivers and Harbors Act. In addition, the bridge 
would require water quality certification from the Regional Water Quality Control Board, under 
Section 401 of the Clean Water Act, and might require a Stream Alteration Permit from the California 
Department of Fish and Game. Because of the federal action and funding, environmental review of the 
bridge must also include completion of a document prepared pursuant to the National Environmental 
Policy Act (NEPA). In addition, the California Public Utilities Commission would have to approve the 
change in rail route and abandonment of track within the Mission Bay project area. Funding 
authorization would be required from the San Francisco Board of Supervisors and the Port Commission 
must also approve the bridge project. A building permit would also be required. 



FUTURE PORT DEVELOPMENT 

The third major category of components within the project description consists of growth in cargo 
shipping at Piers 80 and 94-96 - the Port's two container terminals - and expansion of the Port's dredge 
material handling program, as well as potential future development of several other Port sites, or 
"opportunity areas," in the "backlands" (upshore from) Piers 90-94, and at and near Pier 70. Although 
the Port has not identified specific development proposals for these opportunity areas at this time, the 
Port's Waterfront Land Use Plan does allow future development proposals, and these potential future 
uses are therefore part of the "project" as defined for CEQA purposes, anticipated for the most part to be 



Higher high water is the higher of the two daily high tides. (There are two high and two low tides each day; of the high 
tides, one is higher, and of the low tides, one is lower.) The mean higher high water is the average of the higher high water 
levels over time. 



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implemented by the SEIR horizon year of 2015. The actual range of potential development is broad, 
with widely varying environmental impacts. For analytical purposes, this SEIR assumes relatively 
intensive uses to produce a conservative assessment of environmental impacts. Any actual development 
program or project(s) for the below areas (other than cargo shipping at Piers 80 and 94-96 and Port 
dredge material handling at Pier 94) proposed in the future may be reviewed by a community advisory 
group process set forth in the Waterfront Plan, and would be subject to additional project-specific 
environmental review. 

Following are the development assumptions, with land uses as specified in the Waterfront Land Use 
Plan, that are used in this SEIR to analyze projected activity at these sites, which are shown in Figure 2, 
p. 8. 

CARGO SHIPPING 

As part of the project analyzed in this SEIR, the Port's two container terminals, at Pier 80 and Pier 94-96, 
would potentially accommodate increased cargo shipping activity consisting of handling of both 
containerized and non-containerized cargo. The project therefore would include movement of 
approximately 200,000 TEU^^ of new cargo (beyond existing volumes of approximately 50,000 TEU) in 
addition to the cargo activity associated with the Industry Group leases. Of the 200,000 new TEU, 
30,000 TEU is assumed to be accommodated by 2001, another 20,000 TEU by 2003, and 
150,000 additional TEU by 2015. Cargoes may be containerized or bulk, depending on demand from 
shippers (see note 6, p. 3, for an explanation of different types of cargo). 

DREDGE MATERIAL HANDLING SITE 

The Port has recently begun storing material dredged from the Bay during routine maintenance dredging 
from Piers 35, 80, and 96. (The Port also uses storage sites in the East Bay.) Currently, dredge material 
is placed by crane onto the pier deck within a temporary three-acre enclosure at Pier 96 and allowed to 
drain and partially dry (to about 20 percent moisture content) before being hauled by truck to landfills, 
where it is used as daily cover for solid waste landfilling operations. The (drained) decant water is 
discharged to the Bay. The Port plans to expand this operation and move it to Pier 94, where it would 
occupy up to about five acres of unpaved land north of the paved pier apron. At the new site, about 
20,000 cubic yards of dredge material per year would be pumped from a barge into the drying area. It is 
anticipated that the off-hauling by truck of partially dried dredge materials would occur over a period of 
about two weeks during the year. Trucks would travel on Amador Street. 

PIERS 90-94 BACKLANDS 

This approximately 50-acre area would potentially be developed with a mix of about 650,000 square feet 
of light industrial uses and approximately 1 million square feet of commercial office and/or research and 



See footnote 7, p. 3, for an explanation of TEU (twenty-foot equivalent unit). 



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development uses. Office and/or research and development uses would be anticipated to occur in two- to 
three-story buildings that would be expected to include landscaped open spaces as part of an overall site 
plan. 

PIER 70 

The project analyzed in this SEIR includes development of approximately 200,000 square feet of new 
Maritime Industrial uses and an additional 200,000 square feet of General Industrial uses within the 55- 
acre Pier 70 Maritime Reserve Area. The Waterfront Plan includes Maritime Industry among the uses 
related to waterbome commerce and navigation. Maritime Industry could also include Maritime Support 
uses such as equipment storage and warehousing uses. The Plan defines General Industry as "facilities 
for enclosed and open air industrial activities, including but not limited to: recycling operations, 
automobile repair and related services, bio-remediation, sand and gravel operations, transmission 
facilities, and manufacturing operations." 

PIER 70 MIXED-USE OPPORTUNITY AREA 

The project analyzed in this SEIR includes development of this 16-acre area, between 18th and 21st 
Streets and extending one to three blocks east of Illinois Street. It is anticipated that uses in this area 
would include a mix of uses, including approximately 610,000 square feet of commercial office and/or 
research and development space; 100,000 square feet of retail and other commercial space; and 
240,000 square feet of public access and recreational maritime uses. The Port plans to issue a Request 
for Proposals to potential developers of the Pier 70 Mixed-Use Opportunity Area in late 2000. (An 
alternative considered in this SEIR would include housing on a portion of the Pier 70 Mixed-Use 
Opportunity Area.) 

WESTERN PACIFIC PROPERTY 

The so-called "Western Pacific Property," a former rail yard east of Illinois Street between 25th and 
Cesar Chavez (Army) Streets, will be partially occupied by a Muni Metro maintenance and storage 
facility that will be constructed as part of the soon-to-be undertaken Third Street Light Rail Extension 
project. The Muni Metro facility was analyzed in the EIR/EIS for the Light Rail Project, and will occupy 
about three-fourths of the approximately 25-acre Western Pacific Property. No specific development 
projects are forecast for the remainder of the Western Pacific Property. However, as part of the project 
analyzed in this SEIR it is assumed that part of the remainder of this site would be occupied by General 
Industrial uses, potentially including construction-related uses such as materials storage, on an interim 
basis. 

REFERENCES - Project Description 

NRMCA (National Ready Mixed Concrete Association) website (www.nrmca.org) . Viewed 
December 8, 1999. 



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CHAPTER III 

ENVIRONMENTAL SETTING AND IMPACTS 



A. LAND USE, PLANS, AND POLICIES 

SETTING 



STUDYAREA 

The project site is located within the Southern Waterfront area, which extends from Mariposa Street to 
India Basin, and encompasses the area from the shipyards at Piers 68-70 to the north to Pier 98 to the 
south. The Southem Waterfront area is the heart of the Port's industrial maritime operations. The area 
has the only facilities for containerized cargo on the San Francisco waterfront, and the remaining 
concentration of water-dependent and support activities such as cargo shipping, storage and trucking 
services. The Port's Southem Waterfront Terminals also are equipped to handle breakbulk, neo-bulk, 
and project cargoes. Much of the area is undeveloped or under-developed, such as the large area at 
Pier 70 and the "backlands" inland from the southem container terminal at Piers 94-96. 

The project area is generally bounded by 16th Street to the north, Islais Creek and Cargo Way to the 
south, Third Street to the west and the San Francisco Bay to the east. The project area includes Piers 68 
through 96. For purposes of analysis, the land use impacts study area has been defined as Mission Bay to 
the north, Oakdale Avenue to the south, Arkansas Street to the west and the San Francisco Bay to the 
east. 

EXISTING LAND USES 
Project Area 

The project area contains primarily cargo shipping, ship repair yard, industrial, and service, storage, and 
light industrial uses; open space at Warm Water Cove, along the north and south banks of Islais Creek, 
and at Pier 98, Heron's Head Park; and vacant land. The Port has a dredge materials handling operation 
at Piers 94-96. No residential uses are located within the project area (see Figure 4); the nearest 
residential areas are those in the Bay view-Hunters Point neighborhood, atop Potrero Hill, along Third 
Street, and in the small community known as Dogpatch, west of Third Street near 22nd Street (see Land 
Uses in the Vicinity, below). In the vicinity of the proposed Illinois Street Intermodal Bridge, there are 
existing vacant and industrial/manufacturing uses. 



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SOURCE: Environmental Science Associates, Pittman & Hames Associates. 



J999.377E: Southern Waterfront SEIR (ESA 990267) 



Figure 4 

Generalized Map of 
Existing Land Use 



26 



m. ENVIRONMENTAL SETTING AND IMPACTS 



A. LAND USE, PLANS, AND POLICIES- SETTING 



The proposed sites of the Industry Group project components contain existing, vacant industrial 
buildings, vacant land, and industrial/manufacturing businesses. The Bode Ready-Mix Concrete Plant 
site is a three-acre site at Pier 92 that is currently vacant and undeveloped. The Mission Valley Rock 
Aggregate Terminal site and location of Mission Valley Rock's proposed asphalt plant, located 
immediately west of the Bode concrete site, is a 5.2 acre vacant site, which is adjacent to Mission Valley 
Rock's existing dredge sand processing facility. The British Pacific Aggregates facility would be located 
on a 10-acre site at the Pier 94 cargo terminal, which is also now vacant. ISG Resources proposes to re- 
use two existing now-unused former grain silos at Pier 90. The RMC Pacific Materials site is a 3. 1 acre 
parcel located at the west end of Pier 80, and the southeast comer of Illinois and Marin Streets. The 
existing site is currently paved and used as a storage yard by Marine Terminals Corporation, which 
operates the Port's North Container Terminal at Pier 80. The Waste Resources Technologies site is a 
vacant existing building at Pier 70, located near 20th and Illinois Streets in the former Union Iron Works 
complex. The Coach USA site consists of approximately 8 acres at Pier 96 which is an existing paved 
storage yard (6.9 acres) and an existing building. Cargo shipping activity is accommodated at the Port's 
Pier 80 and Piers 94-96 terminals, which currently do not operate at capacity, while the Port's dredge 
material handling facility occupies about three acres in a temporary location at Pier 96. 

The unprogrammed Port lands on which the project analyzed in this EIR includes future commercial 
development are located in the Port backlands area. Pier 70 contains 55 acres of industrial uses and 
vacant land. The 16-acre Pier 70 Mixed Use Opportunity Area is also occupied by existing industrial 
uses and by vacant land. Three historic Union Irons Works buildings and the Bethlehem Steel 
headquarters building are located at Pier 70 at 20th and Illinois Streets. The "Western Pacific Property," 
now vacant, is a former rail yard east of Illinois Street between 25th and Cesar Chavez (Army) Streets 
consisting of 25 acres. The Piers 90-94 backlands area is approximately 40 acres of vacant, unimproved 
lands that contains temporary or "interim" industrial uses such as metal recycling, concrete crushing, and 
a soils bio-remediation facilities operated by the Department of Public Works. The Warm Water Cove 
open space recreational area is also within the project area, located at the east end of 24th Street. 

Land Uses in the Vicinity 

Land uses in the vicinity of the project site include industrial, manufacturing, residential, recreational and 
institutional uses, as well as two electric power-generating plants, one of which, the Potrero Power Plant 
owned by Southern Energy, while technically outside the study area on non-Port-owned land at the foot 
of 23rd Street, is surrounded by Port lands within the Southern Waterfront. Pacific Gas and Electric also 
owns the Hunters Point Power Plant on Hunters Point Expressway at Evans Avenue, at the southern 
boundary of the project area. 

The approved Mission Bay development is located in the northern portion of the land use study area. 
Mission Bay is planned for commercial, research / development, and bio-tech uses (including a new 
University of Califomia-San Francisco research campus) totaling 8.2 million square feet, and up to 6,000 
residential units. 



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III. ENVIRONMENTAL SETTING AND IMPACTS 

A. LAND USE, PLANS, AND POLICIES- SETTING 

The nearest residential community is located approximately one-fourth mile west of Third Street, in a 
small mixed-use residential and manufacturing enclave commonly known as "Dogpatch." This area is 
located roughly between 20th and 23rd Street between Third Street and Minnesota Street, and contains 
mostly duplexes interspersed with single-family homes and some manufacturing and light industrial 
uses. 

Newer residential loft and live- work units are located on the west side of Third Street near 22nd Street 
and Mariposa Street. The Potrero Hill neighborhood is located west of Third Street between 1-280 and 
U.S. 101, about one and three-fourth miles from the project area. Potrero Hill is a mixed-use 
neighborhood. The lower portion of Potrero Hill contains light industrial and manufacturing uses, with 
some new live/work development. West of Arkansas Street are mostly single-family homes, duplexes, 
public housing, and some multi-family units. The Potrero Hill Recreation Center is located between 
Arkansas and Connecticut Street, near 22nd Street. Esprit Park, a publicly accessible park, is located at 
Indiana and 19th Streets. 

Portions of the Bayview-Hunters Point neighborhood are located approximately one-half mile from the 
project area, south of Evans Avenue and west of Third Street. Bayview-Hunters Point is a well- 
established residential and industrial neighborhood. This portion of Bayview-Hunters Point in the land 
use study area is primarily single family housing and multi-family housing located in Hunters Point, 
including San Francisco Housing Authority properties, with a mixture of commercial, manufacturing and 
retail uses along Third Street. Light industrial, public and manufacturing are located in the India Basin 
Industrial Park, east of Cargo Way, and on Evans Avenue. 

Nearby recreational uses in Bayview-Hunters Point are the Youngblood Coleman Playground located at 
Mendell and Galvez Streets, east of Evans Avenue, and the Hunters Point Community Youth Park on 
Middlefield Road adjacent to the Malcolm X Academy, a private elementary school. 

Several major public facilities and a utility use are located in Bayview-Hunters Point. The Pacific Gas 
and Electric power plant and the U.S. Postal Service distribution center are located in the India Basin 
Industrial Park, between Cargo Way and Evans Avenue. The Southeast Water Pollution Control Plant is 
located on Phelps Street and Evans Avenue, and the Southeast Community College Center is on Oakdale 
Avenue and Phelps Street. 

Planned Land Use Changes 

Several large-scale projects are planned in the greater project area vicinity. As noted in the Project 
Description, the San Francisco Municipal Railway will construct a maintenance and rail car storage 
facility for the Third Street Light Rail Extension project on the Westem Pacific site. Operation of the 
Third Street light rail line, to extend from the Caltrain station at Fourth and Townsend Streets to 
Visitacion Valley, will also include a turnaround track loop at 18th, Third, and Illinois Streets. 



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in. ENVIRONMENTAL SETTING AND IMPACTS 



A. LAND USE, PLANS, AND POLICIES- SETTING 



The Planning Department has undertaken the "Better Neighborhoods 2002" program and is preparing the 
first three neighborhood plans under this effort, including one in the Central Waterfront, which includes 
the area between Mariposa Street and Islais Creek east of Interstate 280, adjacent to and including the 
northern part of the project area analyzed in this SEIR. 

The San Francisco Redevelopment Agency is currently developing a redevelopment plan for the 
Bayview-Hunters Point area, bounded by Cesar Chavez Street to the north, San Francisco Bay to the 
east, the San Francisco city limits to the south and U.S. Highway 101 to the west. This redevelopment 
survey area includes portions of the project area for this SEIR, including Piers 94-96 and Pier 80, as well 
as Islais Creek. In addition, the Agency is beginning implementation of a redevelopment and reuse plan 
for the former Hunters Point Shipyard site, southeast of the SEIR project area. 

Southern Energy California, the operator of the Potrero Power Plant at 22nd and Illinois Streets, has filed 
an application with the California Energy Commission to construct a new natural gas-fired generating 
unit at the plant. This new unit, which would increase the plant's output from 360 megawatts to 900 
megawatts, is anticipated to be operational by 2003 (California Energy Commission, 2000). If approved, 
the expansion of the Potrero Plant is expected to allow for closure of the Hunters Point Power Plant, on 
Evans Avenue just southeast of the SEIR project area. Under an agreement reached in 1998 between 
PG&E, the operator of the Hunters Point plant, and the City, the 429-megawatt Hunters Point plant is to 
be closed when a replacement source of energy is found. PG&E will be responsible for removal of the 
plant and restoration of the site. The City plans to convert the Hunters Point plant site to open space. 



PLANS AND POLICIES 
San Francisco General Plan 

The San Francisco General Plan, Zoning Map, and Planning Code provisions govern all of San 
Francisco. The General Plan contains 10 elements (Commerce and Industry, Recreation and Open 
Space, Residence, Community Facilities, Urban Design, Environmental Protection, Transportation, Air 
Quality, Community Safety and Arts), which contain goals, policies, and objectives for the physical 
development of the City. In addition, the General Plan includes area plans containing objectives and 
policies for specific geographic areas. The project site is located largely within the Central Waterfront 
planning area that extends from Pier 48 to Islais Creek. The Planning Commission and Board of 
Supervisors approved amendments to General Plan language and to the Zoning Map and Planning Code 
to reflect the policies of the Waterfront Land Use Plan for the Southern Waterfront. 



Central Waterfront Plan 

The Central Waterfront Plan, an area plan within the San Francisco General Plan, guides growth and 
development along San Francisco's central waterfront, an irregularly shaped area that includes several 
subareas: Islais Creek, Central Basin, Lower Potrero, North Potrero, Mission Bay, and Showplace 



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ni. ENVIRONMENTAL SETTING AND IMPACTS 

A. LAND USE, PLANS, AND POLICIES- SETTING 

Square. The project area is within the Central Waterfront Plan's Central Basin and Islais Creek planning 
areas. 

The Central Waterfront Plan "calls for development that will meet the City's pressing economic and 
employment needs without sacrificing environmental quality," with an emphasis on industrial 
development to aid in the diversification of the City's economy. The Central Waterfront Plan was 
amended in 1990 to divide the plan into two parts: Part I, which covers all subareas except Mission Bay, 
and Part II, which covers Mission Bay. The overall goal of the Plan for subareas other than Mission Bay 
"is to create a physical and economic environment conducive to the retention and expansion of 
San Francisco's industrial and maritime activities ... in order to reverse the pattern of economic decline 
in the area and to establish a land base for the industrial and maritime components of the San Francisco 
economy." The Central Waterfront Plan was amended in 1997 to accommodate adoption of the Port's 
Waterfront Land Use Plan, and Part II was amended again in 1998 upon adoption of the Mission Bay 
North and South Redevelopment Plans; the second of these amendments did not affect the Central Basin 
or Islais Creek subareas. Objectives and policies of the Central Waterfront Plan (as revised and amended 
in 1990, per Planning Commission Resolution No. 12040, and in 1997, per Planning Commission 
Resolution No. 14467) that are pertinent to the proposed project include the following: 

Land Use 

Objective 1: Strengthen and expand land uses essential to realizing the economic potential of the 
[Islais Creek, Central Basin, Lower Potrero, North Potrero, and Showplace Square] Subareas [i.e., 
those excluding Mission Bay]. 

Objective 1, Policy 1: Encourage the intensification and expansion of industrial and maritime 
uses. 

Objective 1, Policy 2: Preserve and protect the subareas as a land base for San Francisco industry. 
Prevent the conversion of land needed for industrial or maritime activity to non-industrial use. 
Permit only those non-industrial uses which do not interfere with industrial and maritime 
operations. 

Objective 1, Policy 3: Promote new development which has minimal adverse environmental 
consequences. Assure that adverse environmental impacts of new development are mitigated to 
the maximum feasible extent.. 

Objective 2: Maintain and develop additional uses on land determined to be surplus to industrial 
and maritime needs. 

Objective 2, Policy 1: Preserve existing residential uses and develop limited new housing. 

Objective 2, Policy 2: Preserve existing commercial uses and expand as needed to serve increases 
in the working and residential populations. 

Objective 2, Policy 3: Improve, expand, and develop recreational areas at established public 
access points along the waterfront enabling public use and enjoyment of the shoreline. 

Industry 

Objective 3: Retain, expand and protect industrial activity. 



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Objective 3, Policy 1: Promote industrial expansion through maximizing and intensifying the use 
of existing facilities and properties, rehabilitating older industrial structures and developing vacant 
land with industrial uses. 

Objective 3, Policy 2: Encourage the consolidation of rail operations and unnecessary tracks and 
facilities to increase land available for industry. Maintain and, as needed, upgrade rail service to 
San Francisco. 

Objective 3, Policy 6: Encourage the growth of firms which strengthen the maritime or 
complement the maritime operation of the Port, either by directly engaging in maritime activities 
or by providing ancillary services which serve or support maritime activities. 

Objective 3, Policy 10: Assist firms displaced from other parts of San Francisco, especially those 
displaced by downtown office expansion, in locating to the subareas. 

Objective 3, Policy 11: Attract new industries that create employment opportunities for City 
residents, add tax revenues in excess of public service costs and strengthen and diversify 
San Francisco's economic tax base. 

Maritime 

Objective 4: Retain and expand maritime uses along the Central Waterfront shoreline. 

Objective 4, Policy 1: Retain and improve and, if warranted, expand all existing maritime general 
cargo facilities along the Central Waterfront (Piers 48, 50, 70 and 80). 

Objective 4, Policy 2: Retain all existing ship repair operations along the Central Waterfront. 

Objective 4, Policy 4: Reserve land adjacent to the waterfront as required for maritime support 
use. 

Transportation 

Objective 7: Improve the transportation accessibility of the subareas. 

Objective 7, Policy 2: Provide adequate rail and truck access to all maritime piers. 

Objective 7, Policy 3: Establish an official truck route system along the designated major and 
secondary thoroughfares to facilitate truck movements within and to port facilities and other area 
businesses and to minimize the adverse impacts of truck movement on adjacent residential, 
commercial and recreational land uses. 

Objective 8, Policy 5: Require off-street parking facilities for fi-eight loading and service vehicles 
in all major new developments and incorporate these in older buildings where feasible. Provide 
short-term loading spaces on the street for routine deliveries and essential services, with strict 
enforcement of time limits. 

Recreation and Open Space 

Objective 9: Provide public access and recreational opportunities along the shoreline. 

Objective 9, Policy 3: Provide public overlooks, viewing areas, and open spaces with convenient 
pedestrian access in areas of maritime activity, where feasible and where it will not inhibit the 
maritime operations. 

Central Basin Subarea 

Objective 15: Maintain and expand maritime activity in the Central Basin subarea. 



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Objective 15, Policy 3: Preserve and rehabilitate the three Union Iron Works Buildings (located in 
part of the former Bethlehem Steel area on the north side of 20th Street, east of Illinois Street 
which, as historic and architectural resources, represent the importance of the ship building 
industry in San Francisco's development. In order to make adaptive reuse feasible, permit 
revenue-generating commercial and industrial uses which are compatible with ongoing ship repair 
and potential future maritime and industrial operations on adjacent bayward Port property, as 
indicated in the Port of San Francisco' s Waterfront Land use Plan. Design such adaptive reuse 
projects consistent with the Waterfront Design & Access urban design and preservation policies 
and criteria for this area, contained in the Waterfront Land use Plan. 

Objective 16: Retain and expand industrial uses. 

Objective 16, Policy 1: Encourage more intensive use of existing industrial land and facilities in 
locations or for durations which will not foreclose or inhibit development of future container 
facilities. 

Objective 18, Policy 1: Minimize blockage of private and public views and maintain, to the extent 
feasible, sightlines from Potrero Hill and Mission Bay to the waterfront and downtown. 

Islais Creek Subarea 

Objective 19: Expand maritime activity and ancillary services. 

Objective 19, Policy 1: Maintain Pier 80 as a container terminal facility and allow other types of 
cargo shipping or interim uses of this facility when it is not fully utilized for container cargo 
operations. Allow compatible maritime, industrial or commercial uses on the adjacent former 
Western Pacific rail yard, once this site has been acquired by the Port. 

Objective 20: Develop waterfront recreational uses on Islais Creek Channel. 

Objective 20, Policy 1: Develop the Islais Creek Turning Basin west of the Third Street Bridge for 
recreational use, which could include a small craft dock or launching facility, if an when it is not 
longer needed for Port maritime activity. 

Objective 21: Retain and expand industrial uses in the Islais Creek subarea. 
South Bayshore Plan 

The South Bayshore Plan, an area plan within the San Francisco General Plan, governs land use policies 
and objectives for the Bay view-Hunters Point neighborhood, including land south of Islais Creek within 
the project area. The project area, therefore, encompasses portions of the India Basin Industrial Area 
Sub-District, and is adjacent to the Hunters Point and Northern Industrial Area Sub-Districts, of the 
South Bayshore Plan. These areas are also included in the proposed Bayview-Hunters Point 
Redevelopment Project Area, currently under study by the San Francisco Redevelopment Agency for 
future designation as a Redevelopment Area. Policies of the South Bayshore Plan that are pertinent to 
the proposed project include the following: 

Land Use 

Policy 1.2: Restrict toxic chemical industries and other industrial activities with significant 
environmental hazards from locating adjacent to or nearby existing residential areas. 



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Transportation 

Policy 3.1: Improve and establish truck routes between industrial areas and freeway interchanges. 
Policy 4.5: Create a comprehensive system for pedestrian and bicycle circulation. 

Industry 

Objective 8: Strengthen the role of South Bayshore industrial areas in the overall economy of the 
district, the City, and the overall region. 

Policy 8.1: Maintain industrial zones in the Northern Industrial and India Basin sub-districts. 
Policy 9.1: Increase employment in local industries. 

Recreation and Open Space 

Policy 13.1: Assure that new development adjacent to the shoreline capitalizes on the unique 
waterfront location by improving visual and physical access to the water in conformance with 
urban design policies. 

Policy 13.4: Provide new public open spaces along the shoreline - at Islais Creek, Pier 98, India 
Basin. 

Waterfront Land Use Plan 

Approved in June 1997, the Waterfront Land Use Plan (or, "Waterfront Plan")is a land use policy 
document governing property under the jurisdiction of the Port of San Francisco, generally from 
Fisherman's Wharf to India Basin. The Land Use Plan is intended to: 1) actively promote the 
continuation and expansion of industrial, commercial and recreational maritime actives; 2) support new 
and existing open space and public access; 3) recognize the structure of the Port for revenue-generating 
land uses to fund maritime activities, open space, and public activities along the waterfront; 4) adapt to 
fluctuating economic, social and political structures by identifying the range of acceptable uses for Port 
properties; 5) encourage efficient use of currently underutilized Port properties by allowing a range of 
interim uses; and 6) establish a framework for streamlining the entitlement process for new development. 
The Plan also called for identification of City plans and policies in need of reassessment and 
modification to implement the plan; as noted above, the General Plan, Planning Code, and Zoning Map 
have been modified to ensure consistency with the Waterfront Plan. 

The Waterfront Plan has seven goals: 1) to encourage the Port to function as a working Port for cargo, 
shipping, fishing, passenger cruise ships, ship repair, ferry and excursion boats, recreational boating and 
other water-dependent activities; 2) to stimulate new investment that will revitalize the waterfront, create 
jobs, revenues, public amenities, and other benefits; 3) to promote diversity of activities and people 
including maritime, commercial, entertainment, civic, open space, recreational and other waterfront 
activities for all to enjoy; 4) to provide access along the waterfront through a network of parks, plazas, 
walkways, open spaces, and integrated transportation improvements that would enhance enjoyment of 
the Bay environment; 5) to enhance the waterfront's historic character, while creating new opportunities 
for San Franciscans to integrate the waterfront into their everyday lives; 6) to ensure appropriate quality 
of urban design along the waterfront; and 7) to provide economic access to all people in San Francisco. 



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In addition, the Waterfront Plan includes land use objectives for five sub-areas, including the Southern 
Waterfront, that specifically address the overall goals and objectives of the land use plan. 

Southern Waterfront Sub-Area 

The Waterfront Land Use Plan contains the following objectives for the Southern Waterfront. 

• Maximize the utilization of existing cargo terminal facilities. 

• Pursue financing mechanisms to develop competitively prices maritime support facilities in the 
Southern Waterfront. 

• Maximize the productivity of Port assets through interim use of property reserved for maritime 
expansion. 

• Development of non-maritime land uses that would be beneficial to the Port and compatible with 
maritime activities should be considered in areas which are surplus to long-term maritime needs. 

• Promote non-maritime activities in and around three historic Union Iron Works buildings to facilitate 
the revitalization of an area that survives as an example of San Francisco's earliest maritime 
industry. 

• Reserve or improve areas which will provide opportunities for the protection of wildlife habitat and 
for passive and active recreational uses. 

• Enhance the public's appreciation of the waterfront by providing greater opportunities for access in a 
manner which does not compromise the efficiency of maritime operations. 

The Waterfront Plan specifies acceptable land uses by the location at which they may be developed in the 
Southern Waterfront, including new uses, those that may be continued as an interim use, or those that 
may be permitted as an accessory use. Generally, a wide variety of Maritime Uses (e.g., cargo shipping, 
maritime office and support services, and ceremonial berthing), Open Space/Recreation, and 
Commercial, and Other Uses, including general institutional and power plant uses, are permitted on 
specified sites throughout the project area. On Pier 84, west of Third Street on Islais Creek, a range of 
uses is permitted, including maritime, residential, and commercial. . No hotels are permitted in the 
Southern Waterfront. Acceptable uses for the project area are summarized in Appendix B, Land Use. 

Site-specific development standards are also provided in the Waterfront Plan to guide improvements to 
Opportunity Areas, which encourage a mixture of maritime, open space and public access activities 
which bring day and nighttime activities to the waterfront. The Plan contains Opportunity Areas in the 
Southern Waterfront at Pier 70, at the Western Pacific Site, and northeast of Cargo Way in the Piers 94- 
96 "backlands." 

Sustainability Plan 

The Sustainability Plan for the City of San Francisco was endorsed by the Board of Supervisors on 
July 21, 1997 (Resolution No. 692-97), as a non-binding guideline for policy and practice in the City and 
County. The City's Department of the Environment was formed to address sustainability issues, 
including implementing the Sustainability Plan. The basic goal of the Sustainability Plan is to enable the 



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City and its people to meet its present needs without sacrificing the ability of future generations to meet 
their own needs. Although there is no specific "land use" topic, a number of Sustainability Plan 
objectives have land use implications, particularly those related to building design, landscaping, 
transportation, and neighborhood design. The proposed project would not obviously or substantially 
conflict with the Sustainability Plan. 

Bay Conservation and Development Commission 

The San Francisco Bay Conservation and Development Commission (BCDC) is a state agency with 
permit authority over the Bay and its shoreline. BCDC, created by the McAteer-Petris Act in 1965, has 
authority to regulate filling, dredging, and changes in use in San Francisco Bay and to regulate new 
development within the 100 feet of the shoreline to ensure that maximum feasible public access to the 



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Bay is provided. The Commission is also charged with ensuring that the limited amount of shoreline 
property suitable for regional high priority water-oriented uses (ports, water-related industry, water 
oriented recreation, airports and wildlife areas) is reserved for these purposes. Proposed land uses and 
structural changes are govemed by policies regarding public access. BCDC can require, as conditions of 
permits, shoreline public access improvements consistent with a proposed project, such as, but not 
limited to, pathways, observation points, bicycle racks, parking, benches, landscaping, and signs. 

Of primary concern to BCDC is the placement of new "fill" (generally defined as any material in or over 
the water surface) in the Bay for the purposes of new development. The McAteer-Petris Act imposes 
very strict standards for the placement of fill. Placement of fill may be allowed only for uses that are: (1) 
necessary for public health, safety or welfare; (2) water-oriented uses, such as water-dependent industry, 
water-oriented recreation, public assembly, and the like; or (3) minor fill to improve shoreline 
appearance and public access. Fill must be the minimum necessary for the purpose and can be permitted 
only when no alternative upland location exists. With the exception of the proposed Illinois Street 
bridge, none of the project components would involve bay fill. 

Planning Documents 

Major BCDC planning documents applicable to the Southern Waterfront include the San Francisco Bay 
Plan, adopted in 1969 and since amended, which specifies goals, objectives and policies for existing and 
proposed waterfront land use and other BCDC jurisdictional areas; the Bay Area Seaport Plan, prepared 
in conjunction with the Metropolitan Transportation Commission, which is BCDC's overall policy for 
long-term growth and development of the Bay Area's six seaports, including the Port of San Francisco; 
and the San Francisco Waterfront Special Area Plan, which indicates acceptable land uses in much 
greater detail than does the regional Bay Plan. The Special Area Plan designates all of the proposed 
Industry Group sites as port priority areas that should be reserved for marine terminals and directly 
related activities. However, the most recent update of the Seaport Plan (adopted April 18, 1996, and 
amended September 18, 1997), has removed the Western Pacific site from port priority area designation. 
Additionally, most of the Pier 90-94 backlands, identified for future mixed-use development in this 
SEIR, has also been removed from port priority area status. Most of the proposed Industry Group project 
components are proposed to be located outside the 100-foot band of BCDC jurisdiction, and thus would 
not require BCDC approval. Exceptions may include a portion of the RMC Pacific component at Pier 
80, a portion of the Mission Valley Rock component at Pier 92, and a portion of the British Pacific 
Aggregates component. In each case, however, the portion of the project component that would be 
within the shoreline band would be devoted to receiving of waterbome construction aggregate material, 
which would be considered a maritime use. The Illinois Street bridge over Islais Creek would fall within 
BCDC jurisdiction and would require a Coastal Zone consistency determination from BCDC under the 
federal Coastal Zone Management Act. 

The Port and BCDC recently completed a joint agreement concerning the acceptability of certain land 
uses, provisions for open space and public access, and other issues. However, this agreement applies to 
waterfront areas north of China Basin Channel and thus does not concern the Southern Waterfront. 



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The Public Trust Doctrine 

The City and County of San Francisco, through the Port Commission, holds title to Port lands in trust for 
the people of the State of California. This is because the State, upon admission to the United States in 
1850, was granted title to all submerged lands and tidelands, and Port property sits atop former tidelands 
that have been filled. The area now known as the Port of San Francisco was governed by a State Harbor 
Commission until 1968. At that time, the State adopted the Burton Act, which enabled transfer of the 
area to the City and County of San Francisco to be held in trust for the people of California for the 
purposes of maritime commerce, navigation and fisheries (the "public trust"), and uses that enhance 
natural resources or attract people to use and enjoy the Bay. The Burton Act granted the Port broad 
powers relative to the transferred property. There are, however, three key constraints: (1) property 
cannot be sold or otherwise transferred into private ownership, unless the State Legislature finds that the 
property is valueless for trust purposes, is proposed for a beneficial public use, and is a small portion of 
the total land held in trust by the Port; (2) the properties cannot be leased for a period exceeding 
66 years; and (3) the revenues derived from the operation of the leased property must be maintained in a 
separate account and used only for trust purposes. The Port Commission may determine that Port 
property is surplus to trust purposes and may exchange that land for other property and/or use it for other 
purposes determined by the Port Commission and the State Lands Commission to be in the public 
interest. It is also acceptable for the Port to establish short-term leases (generally 10 years or less) for 
non-trust purposes if the property is not required for trust purposes. The proposed Industry Group 
project components would be considered interim or maritime uses. 



IMPACTS 

SIGNIFICANCE CRITERIA 

The City has not formally adopted significance standards for land use impacts, but it generally considers 
that the implementation of the proposed project would have a significant land use impact if it were to: 

• substantially disrupt or divide the physical arrangement of an established community; 

• substantially conflict with established recreational, educational, religious, or scientific uses; or 

• have a substantial impact on the existing character of the community. 

The project could also have a significant effect if it would conflict with any applicable land use plan, 
policy, or regulation of an agency with jurisdiction over the project (including, but not limited to the 
general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of 
avoiding or mitigating an environmental effect, resulting in an adverse physical impact on the 
environment. Conflict with a General Plan policy does not, in itself, indicate a significant effect on the 
environment within the meaning of CEQA. As stated in the State CEQA Guidelines, "Effects analyzed 
under CEQA must be related to a physical change" (Sec. 15358(b)). To the extent that physical impacts 
may result from such conflicts, such physical impacts are analyzed in this SEIR. The General Plan 



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contains many policies, which may address different goals. Upon reviewing projects requiring its 
approval, the Planning Commission must decide whether, on balance, the project is consistent with the 
General Plan. In general, potential conflicts with the General Plan are considered by decision-makers (in 
this case, the Port Commission will be the primary decision-maker concerning the proposed Industry 
Group leases and potential future on other Port lands), independently of the environmental review 
process, as part of the decision to approve, modify or disapprove a proposed project. Any potential 
conflict not identified here could be considered in that context, and would not alter the physical 
environmental effects of the proposed project. 



IMPACT ANALYSIS 

This section describes potential effects of the proposed project on land use, and local plans and policies. 
Potential effects are described separately for each of the project components as defined in Chapter II, 
Project Description. 

Industry Group Projects 
Land Use 

Six private entities would lease sites or facilities in the project area. All but one of these operations 
would be related to the construction industry, and that one entity proposes to lease a site for bus storage, 
maintenance and repair. These facilities are interim uses assumed to have leases with the Port at least to 
2015. Most of the proposed lessees are currently located at existing sites at other locations in 
San Francisco, and would relocate to the project area. Two of the existing sites (Bode and RMC Pacific) 
are within the land use study area at Third and 16th Streets and Third and Mariposa Streets, respectively, 
while ISG Resources currently imports a small amount of fly ash to the project area. Coach USA is at 
8th and Harrison in the South of Market Area, and Waste Resource Technologies formerly operated a 
construction materials recycling facility at Candlestick Point in Bay view-Hunters Point. In addition. 
Mission Valley Rock currently operates a dredge sand processing facility at Pier 92, adjacent to its 
proposed marine aggregate terminal and asphalt plant. The relocation and location of the Industry Group 
operations would be a continuation, rehabilitation or expansion of industrial uses in the Southern 
Waterfront. Therefore, the Industry Group component of the project would not disrupt or divide the 
physical arrangement or impact existing character of other industrial uses in the project area or nearby 
residential communities. The closest residential communities are Dogpatch, located one fourth nule west 
of Third Street, and portions of Bay view-Hunters Point, located one-half mile south of Evans Avenue. 

The majority of the Industry Group components would include a maritime component in their operations, 
and therefore would be considered maritime tenants of the Port. RMC Pacific, British Pacific 
Aggregates, and Mission Valley Rock would import raw materials for concrete and asphalt production by 
ship and barge, and ISG Resources is likely to use waterbome transportation in the future. Bode Gravel 
and Mission Valley Rock (and potentially British Pacific Aggregates), would produce construction 
materials using these waterbome raw materials. 



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None of the existing Industry Group projects would conflict with established recreation and open space 
uses in the area. Four of the projects would be located at least partially in existing warehouse or 
industrial buildings (Mission Valley Rock, ISG Resources, Waste Resources Technologies, and Coach 
USA). The remaining facilities would be located at project area sites that do not encroach on existing 
recreation uses at Warm Water Cove and Islais Creek, and wetlands located near Pier 94: Pier 80 (RMC 
Pacific), Pier 92 (Bode Gravel), and Pier 94 (British Pacific Aggregates). In light of the above, the 
Industry Group uses would have a less-than-significant land use impact. 

Plans and Policies 

The Industry Group project components address several Waterfront Plan objectives for the Southern 
Waterfront subarea. The Industry Group project components would help maximize the utilization of 
existing cargo terminal facilities. Five of the Industry Group members are relocating to the project site 
to maximize access to shipping facilities, either for immediate or potential future cargo shipping use. 
The Industry Group projects would also maximize the productivity of Port assets through interim use of 
property reserved for maritime expansion. Given the heavy industrial operations of the proposed 
facilities, none of the projects would provide on-site public open space access. Development of the 
Waste Resources Technologies site would promote non-maritime activities around the historic Union 
Iron Works buildings as stated in the Southern Waterfront land use objectives. 

The Industry Group project would not obviously conflict with applicable policies of the Central 
Waterfront Plan or the South Bayshore Plan. Development of the projects would be consistent with 
Central Waterfront Plan Objective 1 and its policies. Objectives 15, 16, 19, and 21, and with South 
Bayshore Plan Policy 8.1, to maintain and expand industrial activities in the Central Basin and Islais 
Creek subareas of the Central Waterfront and the Northern Industrial and India Basin sub-districts of the 
South Bayshore. The projects would not create substantial new employment as most of the facilities 
would transfer existing employees from existing San Francisco or Bay Area locations. However there 
could be a marginal increase in employment by these local industries as called for by Policy 9.1 of the 
South Bayshore Plan. Relocation of existing concrete plants from the Mission Bay area would be 
consistent with Central Waterfront Plan Objective 3, Policy 10, to assist firms displaced from other parts 
of San Francisco. 

The Industry Group Projects would include the construction of six facilities primarily for the production, 
shipping, distribution, and storage of materials used in the construction industry, including concrete, 
asphalt, fly ash, sand and gravel. In addition, a construction materials recovery (recycling) facility and a 
charter bus storage yard and service/repair facility would be developed. Each of these facilities are 
acceptable uses under the Maritime and Other Uses Land Use categories of the Waterfront Land Use 
Plan Southern Waterfront sub-area (refer to Appendix B, for a detailed listing of acceptable uses for the 
project area). 

As described in Chapter II, Project Description, all of the Industry Group components are in a M-2 
(Heavy Industrial) Use District and a 40-X Height and Bulk District, and all would be consistent with the 



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M-2 Use District and the 40-X Height and Bulk District.^^ Each of the Industry Group components must 
obtain Port Commission approval of a lease authorizing the proposed uses, and any non-maritime lease 
exceeding $1 million in Port revenue or with a term of 10 years or more would also require approval by 
the Board of Supervisors. BCDC approval would be required for all components within 100 feet of the 
shoreline. Other approvals required would include a General Storm Water Permit from the Regional 
Water Quality Control Board (with a requirement to prepare a Storm Water Pollution Prevention Plan), 
and industrial facilities such as the proposed concrete and asphalt plants would require an Authority to 
Construct and a Permit to Operate from the Bay Area Air Quality Management District. City permits 
would include an industrial sewer discharge permit from the Public Utilities Commission and, where 
applicable, a Hazardous Material Storage Permit from Fire Department, as well as building permit(s) 
from the Port. 

As noted in the Land Use discussion above, most of the Industry Group components would include a 
maritime component in their operations, either import or use of construction-related aggregate materials, 
or both. The only two components without maritime activities. Coach USA's bus storage and 
maintenance facility and Waste Resource Technologies' materials recovery facility, would be interim 
uses and would not displace any maritime activity. Therefore, the Industry Group components would not 
interfere with the port priority area designations of their sites in the Bay Area Seaport Plan. 

In light of the above, the Industry Group components of the project would not obviously or substantially 
conflict with applicable plans and policies. 

Illinois Street Intermodal Bridge 

Land Use 

The proposed Illinois Street bridge would be constructed across the Islais Creek channel, one block east 
of the existing Levon Hagoop Nishkian drawbridge on Third Street. The existing drawbridge would 
remain operational, but would no longer be operated except for testing and maintenance, as the proposed 
new bridge would be a "lift-segment" bridge designed to be opened only infrequently, primarily for 
passage of maintenance vessels and barges. The proposed new bridge would provide the following three 
functions: 1) a direct rail connection between the Port's North Container Terminal facilities on the north 
side of Islais Creek at Pier 80 and the South and Intermodal Container Terminal facilities on the south 
side of Islais Creek; 2) a more direct route for rail cargo to and from Pier 80, to avoid a circuitous route 
that currently extends north through the Mission Bay development site ; and 3) a direct truck connection 
between the two container facilities, avoiding the need for trucks to travel on Third Street. In addition, 
the bridge would provide for bicycle access in the traffic lanes when no trains are crossing the bridge. 



Although some Industry Group components would exceed 40 feet in height, these features would either consist of existing 
buildings that would not be substantially modified or, in the case of concrete batching plants, would be exempt from the 
height limit (Planning Code Section 260(b)(2)(M)). 



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The new bridge would improve the connection between the two container facilities at the Port. The 
Illinois Street bridge would not disrupt or divide the physical arrangement of an established conmiunity, 
nor would it affect the existing character of the community. The bridge could enhance recreational uses 
by improving bicycle access to the Islais Creek Channel and Warm Water Cove. The bridge would also 
be a future link to the San Francisco Bay Trail. Currently, portions of Illinois Street and Cargo Way are 
designated Bay Trail Bicycle Routes, and the bridge would connect these roadways. 

The new lift-segment bridge would not be opened to permit the passage of large pleasure craft or 
sailboats, which can currently be accommodated by the existing Third Street drawbridge. However, 
Department of Public Works bridge logs shows that the Third Street bridge is raised only about six times 
per month, including once weekly for testing the mechanism (which would continue) and twice a month 
for passage of a vessel used in conducting water quality sampling by the Clean Water Program (the 
City's wastewater treatment agency). If the need remains to continue water sampling following 
construction of the new bridge, this activity could be accomplished using a smaller skiff, which could 
pass beneath the new bridge and the existing bridge, even if closed. The only other existing activity that 
requires opening the existing Third Street bridge is periodic passage - about twice a year - by one of the 
Fire Department's fire boats so the crew can take depth soundings in the western portion of Islais Creek 
to ensure that the creek remains navigable for the fire boats. As noted in the Project Description, 
however, fire boat access will no longer be necessary with completion of the new bridge, which includes 
improvements in the water supply system west of Third Street for firefighting. 

Small recreation craft such as canoes, kayaks, an other small vessels (e.g., rowboats) would be able to 
pass beneath the new lift-segment bridge while it is closed. These vessels could use the channel both 
east and west of Third and Illinois Streets, as well as gain access to a ramp and public launch for hand- 
launch craft along Islais Creek west of Third Street. The elimination of larger commercial vessels and 
larger pleasure craft from navigation of the channel at this location is not considered a substantial 
conflict with established recreational uses, as there has been no such activity for more than 10 years, nor 
does the Port believe there is currently substantial demand for the use of the channel west of Third Street 
by larger vessels. The Port has jurisdiction over the Islais Creek channel and has no plans to build or 
approve new facilities acconmiodating large pleasure craft or sailboats west of Third Street. Therefore, 
for all of these reasons, the Illinois Street lift-segment bridge component would have a less-than- 
significant impact on land use. 

Plans and Policies 

The Illinois Street Intermodal Bridge would not substantially or obviously conflict with applicable 
objectives of the San Francisco General Plan or the Waterfront Land Use Plan objectives for the 
Southern Waterfront. The bridge would help maximize the utilization of existing cargo terminal 
facilities at Piers 80 and 94-96 by creating more direct and efficient rail and truck access to the Port 
container facilities on the north and south sides of Islais Creek. As proposed, the bridge would not 
include sidewalks, because land uses north and south of the bridge are and will continue to be largely 
devoted to industrial activity, and because there are sidewalks on the existing Third Street bridge, one 



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block west. Therefore, the bridge would improve waterfront and shoreline access only by providing for 
bicycle access across Islais Creek.25 The bridge would be an acceptable maritime use as it supports 
marine cargo and handling facilities (refer to Appendix B, for a detailed listing of acceptable uses for the 
project area). 

Construction of the Illinois Street bridge would also not conflict with applicable Transportation policies 
of the Central Waterfront Plan or South Bayshore Plan, as it would improve rail access to and between 
the Port's container terminals and improve truck access between industrial areas and freeway 
interchanges, thereby enhancing circulation in the area. As noted, the Illinois Street bridge would 
preclude active use of the Islais Creek Turning Basin - west of Third Street - for boating activities, 
except for very small craft. 

As noted in Chapter II, Project Description, design and construction of the Illinois Street bridge would be 
subject to approval of a bridge permit by the U.S. Coast Guard, which must determine the future 
navigational needs of Islais Creek before it issues a permit. The Coast Guard would determine whether a 
lift-segment span is appropriate. The bridge would also require approval by BCDC because it would be 
constructed over the Bay and within the 100-foot band along the San Francisco Bay shoreline over which 
BCDC has jurisdiction. BCDC would also be required to find that the bridge is consistent with the 
federal Coastal Zone Management Act. Approval would also be required from the U.S. Army Corps of 
Engineers under Section 404 of the federal Clean Water Act (including consultation with the U.S. Fish 
and Wildlife Service) and Section 10 of the federal Rivers and Harbors Act. In addition, the bridge 
would require water quality certification from the Regional Water Quality Control Board, under 
Section 401 of the Clean Water Act, and would probably require a Stream Alteration Permit from the 
California Department of Fish and Game. Because of the federal action and funding, environmental 
review of the bridge must also include completion of a document prepared pursuant to the National 
Environmental Policy Act (NEPA). 

No substantial conflicts with BCDC policies or other regulatory requirements have been identified that 
would prevent a finding of consistency under the Coastal Zone Management Act or other regulatory 
approvals. Further consultation with agencies with jurisdiction may lead to minor modifications of the 
Illinois Street bridge proposal or imposition of specific conditions of approval. Considerations by other 
agencies would also necessitate additional public notice and afford additional opportunities for public 
input. 

Potential Future Port Development 

Land Use 

Consistent with the Waterfront Land Use Plan, Pier 80 and Piers 94-96 would support increased future 
maritime activity for both containerized and non-containerized cargo. Some of the additional cargo 

An existing open space feature along the north side of Islais Creek permits pedestrians to traveJ between Third and Illinois 
Streets. 



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shipping would be associated with cargo activity proposed by several Industry Group members, 
including the British Pacific Aggregates lease at Pier 94, and could result from future cargo shipping 
activity associated with proposed Port leases by Bode, Mission Valley Rock, ISG Resources and RMC 
Pacific. These uses would not disrupt or divide the physical arrangement of the adjacent Port uses or 
nearby residential and commercial communities, as they would represent a continuation of existing Port 
activity. The Port uses would therefore have a less-than-significant land use impact. 

With regard to non-cargo activity on Port lands, Pier 70 would be developed into approximately 200,000 
square feet of new Maritime Industrial uses and an additional 200,000 square feet of General Industrial 
uses within the Pier 70 Maritime Reserve Area. As defined by the Waterfront Land Use Plan, Maritime 
Industrial uses could include equipment storage and warehousing uses, whereas General Industry could 
include recycling operations, automobile repair, bio-remediation, sand and gravel operations, 
transmission facilities and manufacturing operations. These uses would be a continuation and expansion 
of existing maritime and industrial operations on Port property in the Southern Waterfront. These uses 
would not disrupt or divide the physical arrangement of project area uses or nearby residential 
communities, as development would occur entirely on Port property near similar maritime and industrial 
uses. 

The Pier 70 Mixed Use Opportunity Area would be developed into a mixed-use area including 
approximately 610,000 square feet of commercial office and/or research and development uses; 
100,000 square feet of retail and other commercial space; and 240,000 square feet of public access and 
recreational maritime uses. Development of the Pier 70 Mixed Use Opportunity Area would introduce 
new, non-maritime related uses in the Southern Waterfront. However such uses would not conflict with 
nearby maritime-related and industrial uses. Mixed use development on the Pier 70 backlands would not 
disrupt or divide the physical arrangement of the project area uses or nearby residential communities. 
The new uses introduced on the Pier 70 backlands would change the existing character in this section of 
the Southern Waterfront area, but would have a less-than-significant impact on the existing land use 
character of Southern Waterfront uses, and would have no adverse impact on the character of 
surrounding residential communities. Rather, the mixed-use area would serve as a buffer between 
maritime and industrial uses nearest the water and residential uses on Potrero Hill and in Dogpatch. The 
creation of 240,000 square feet of public access and recreational uses would create new recreational 
opportunities for nearby residents and the City as a whole. These uses would not conflict with 
established recreation uses at Warm Water Cove and Islais Creek. 

The Piers 90-94 Backlands areas would be developed into a mix of about 650,000 square feet of light 
industrial uses. In addition, approximately 1 million square feet of commercial office and/or research 
and development uses would be developed in two- to three-story buildings, with landscaped open space. 
This type of office park development would not disrupt or divide the physical arrangement of existing 
Port uses, or nearby residential communities, but would affect the existing character of the area. This 
impact is not considered to be substantial, and would be consistent with development in the adjacent 
India Basin Industrial Park, located immediately southwest of the backlands site, across Cargo Way. 



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A. LAND USE, PLANS, AND POLICIES- IMPACTS 



Potential impacts on the character of the area would be minimized by the configuration of the site plan 
and architectural design of the development consistent with the Design and Access Element of the 
Waterfront Plan. The provision of landscaped areas would create new open space opportunities, and 
would not be in conflict with established recreational areas in Warm Water Cove, Islais Creek, and 
Pier 98 (Heron's Head Park). As with the Pier 70 Mixed Use Opportunity Area, these office and 
research and development uses would serve as a buffer between maritime and industrial uses along the 
Bay and residential areas on the hill south of Evans Avenue. For the above reasons, this impact would be 
less than significant. 

Plans and Policies 

Development of currently unprogrammed Port lands would not substantially conflict with adopted plans 
and policies. Maritime related development on Piers 70, 80 and 94-96 would help maximize the 
utilization of existing cargo terminal facilities. Mixed use commercial, office and retail development on 
Pier 70 and Pier 94 backlands would promote non-maritime land uses that could be beneficial to the Port 
and compatible with maritime activities in areas which are surplus to long-term maritime needs, although 
introduction of office or research and development uses outside the Cargo Way, Western Pacific, or 
Pier 70 Opportunity Areas would require amendment of the Waterfront Plan to permit such uses. (Retail 
uses could also be permitted, as accessory uses, at Warm Water Cove, Pier 80, and Piers 94-96.) 
Development of the Mixed Use Opportunity Area at Pier 70 east of Illinois Street would promote non- 
maritime activities around the historic Union Iron Works buildings, and facilitate the revitalization of an 
area that survives as an example of San Francisco's earliest maritime industry. 

The creation of new public access, recreational maritime uses, and landscaped open space in the mixed 
use opportunity areas would be consistent with the Southern Waterfront objectives to improve areas 
which will provide opportunities for passive and active recreational uses, and would enhance the public's 
appreciation of the waterfront by providing greater opportunities for access in a manner which does not 
compromise the efficiency of maritime operations. 

Development of the unprogrammed Port lands would not generally conflict with the policies of the 
Central Waterfront Plan or South Bayshore Plan. Specifically, maritime development at Pier 70 would 
address Central Waterfront Plan objectives and policies to maintain and expand industrial activities in 
the Central Basin and Islais Creek subareas, and to maintain and develop additional uses on land 
determined to be surplus to industrial and maritime needs. Additional maritime activity at Piers 94-96 
would be consistent with South Bayshore Plan Policy 8.1 to maintain industrial zones in the Northern 
Industrial and India Basin sub-areas. This component of the project would also have the opportunity to 
increase employment in local industries as called for in Policy 9.1 of the South Bayshore Plan. The 
creation of 240,000 square feet of new public access and recreational uses near Pier 70 would be 
consistent with Central Waterfront Plan Objective 9. 

As noted in the setting, the most recent update of the Bay Area Seaport Plan removed the Western 
Pacific site from port priority area designation and. most of the Pier 90-94 backlands has also been 



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removed from port priority area status. Therefore, anticipated future Port development would not 
interfere with the port priority area designations of their sites in the Bay Area Seaport Plan. 



REFERENCES - Land Use, Plans And Policies 

California Energy Commission, 2000, at www.energv.ca.gov/siting cases/potrero/index.html 

Port of San Francisco, Waterfront Land Use Plan, adopted June 1997. (Republished January 2000). 

City and County of San Francisco, San Francisco General Plan, including Central Waterfront Plan 
(amended through January 1998), and South Bayshore Plan, July 1995. 



B. TRANSPORTATION 

SETTING 

Within the project area. Third Street is designated in the Transportation Element of the San Francisco 
General Plan as a Major Arterial and a Transit Preferential ("Transit Important") Street. Major arterials 
are defined as "cross-town thoroughfares whose primary function is to link districts within the City and 
to distribute traffic from and to the freeways" (Transportation Element, Table 1). On Transit-Important 
Streets, "the emphasis should be on moving people and goods, rather than on moving vehicles" 
(Transportation Element, Table 4). Third Street is also designated a Major Arterial within the County 
Congestion Management Network, established consistent with state congestion management legislation, 
and is included in the City's Metropolitan Transportation (MTS) street network, which is part of a 
regional network that includes streets and highways that meet criteria established by the Metropolitan 
Transportation Commission. Cesar Chavez (Army) Street and Evans Avenue (west of Third Street) are 
also Major Arterials in the General Plan and Congestion Management Network and are MTS streets. 
Other MTS streets include Cargo Way and Jennings Street between Evans and Cargo; Evans (east of 
Third), Cargo, and Jennings are Secondary Arterials in the General Plan. Illinois Street between 
Mariposa and 24th Streets, Third Street south of 24th Street, and Cargo Way are part of the City wide 
Pedestrian Network by virtue of being on the route of the Bay Trail. Third Street is also a Neighborhood 
Pedestrian (Neighborhood Commercial) Street and a Bicycle Route (Route 5). Cesar Chavez Street 
(Route 60), Evans Avenue (Route 68), Mariposa Street (Route 23), and Phelps and Indiana Streets 
(Route 7) are also bicycle routes. 

Third Street has three travel lanes in each direction, with left turn pockets at Cesar Chavez Street 
(northbound) and Cargo Way and Evans Avenue (southbound). Cargo Way has two travel lanes in each 
direction, divided by a median. Other streets in the area have a single lane in each direction. On-street 
parking is generally permitted, with certain exceptions, throughout the study area. On-street parking is 
available in most parts of the study area. Existing levels of service at study intersections in the project 
area are given in Table 4, p. 53. 



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San Francisco Municipal Railway (Muni) service in the project area is limited. The primary service is 
via the 15-Third line, which links Visitacion Valley with downtown, Chinatown, North Beach, and 
Fisherman's Wharf. Crosstown service is provided on the 19-Polk line, which operates on Evans 
Avenue; the 48-Quintara/24th Street, which operates on 22nd Street; and the 22-Fillmore, which runs on 
18th Street. The Caltrain peninsula coimnute service has a station at 22nd and Pennsylvania Streets; not 
all trains stop at the 22nd Street Station. 

Pedestrian traffic is relatively light in the study area. Third Street has 10-foot sidewalks on each side, 
and Illinois Street (north of 25th Street) also has sidewalks on each side. There are also sidewalks on the 
existing Third Street drawbridge over Islais Creek. Most of the numbered east-west streets have 
sidewalks on at least one side. South of Islais Creek, Cargo Way has sidewalks on each side, but 
Amador Street does not have sidewalks. Third Street has a fair amount of bicycle traffic, particularly 
commuters to and from downtown. Counts conducted in 1996 indicated approximately 50 bicycles per 
hour during both the morning and afternoon peak hours (FTA and San Francisco Planning Department, 
1998, p. 3-25). As noted in the first paragraph under Setting, above, there are several designated bicycle 
routes in the project area. The only striped bicycle lane at present is on Cesar Chavez Street, between 
Third Street and Evans Avenue. 



PLANNED TRANSPORTATION IMPROVEMENTS 

The Third Street Light Rail Extension project, scheduled for construction beginning in 2001, will extend 
Muni Metro light rail service from the Caltrain Station at Fourth and Townsend Streets along Third 
Street to Visitacion Valley. This segment is expected to be operational by 2004. In the project area, the 
light rail tracks will be in a dedicated center median of Third Street, and thus construction of the light rail 
line will remove one travel lane in each direction from Third Street, leaving two vehicle lanes in each 
direction, with a parking lane on either side, except between Cesar Chavez Street and Cargo Way, where 
parking is not permitted. On-street parking will also be eliminated on both sides of Third Street where 
station platforms are constructed. In the project area, stations will be constructed at Mariposa Street, 
20th Street, 23rd Street, Cesar Chavez Street, and Evans Avenue. As part of the light rail project, all 
major intersections will be signalized and signal timings adjusted; lane configurations are also approved 
at several of the intersections analyzed in this SEIR. On-street parking will also be eliminated where 
left-turn lanes are created. These changes are described in Appendix C. The light rail project also will 
include a loop track at Third and Eighteenth Streets that will allow light rail vehicles to turn around and 
head back north on Third Street after passing through the Mission Bay area, and a light rail vehicle 
storage and maintenance facility at the Western Pacific site at 25th and Illinois Streets. 

Another planned Municipal Railway project is the construction of a new bus storage yard at Cesar 
Chavez and Indiana Streets, on the north side of Islais Creek west of Third Street. This yard will replace 
Muni's existing Kirkland bus yard at Powell and North Point Streets, near Fisherman's Wharf, and will 
be adjacent to an existing interim bus yard at Marin and Indiana Streets. 



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Traffic signals were previously identified as mitigation for the approved Mission Bay project at two 
other currently unsignalized intersections studied in this SEIR: Mariposa and Minnesota Streets 
(assumed in this analysis to be signalized by 2003) and Mariposa Street and the 1-280 southbound on- 
ramp (assumed to be signalized by 2015). In addition, the Mission Bay project will allow traffic to cross 
Mariposa Street to the north at both the 1-280 northbound off-ramp and at Minnesota Street, resulting in a 
fourth approach being added at each of these two intersections. 

The Illinois Street Intermodal Bridge over Islais Creek, a component of the project analyzed in this 
SEIR, will include improvements to Illinois Street between Islais Creek and Marin Streets, where the 
pavement is narrow and in poor condition, to accommodate truck traffic crossing the proposed new 
bridge. Separately, Illinois Street will also be improved between Cesar Chavez and 25th Streets - a 
block that is currently unpaved - as part of the Muni light rail vehicle yard described above. This SEIR 
assumes that the remaining block of Illinois Street that is not fully improved, between Cesar Chavez and 
Marin Streets, where only one lane is currently paved, will be fully improved by the time the Illinois 
Street bridge is completed. 



IMPACTS26 



SIGNIFICANCE CRITERIA 

City policy has been that a project is considered to have a significant effect on the environment if it 
would cause a signalized intersection to deteriorate to an unacceptable level of service (i.e., from Level 
of Service (LOS) D or better to LOS E or F, or from LOS E to LOS F),27 interfere with existing 
transportation systems causing substantial alteration to circulation patterns or causing major traffic 
hazards, or contribute substantially ("considerably") to cumulative traffic increases that cause 
intersections that would otherwise operate at acceptable levels to deteriorate to unacceptable levels. The 
City has not formally adopted significance criteria for potential impacts related to transit, but City policy 
has been that a project would have a significant effect if it would cause a substantial increase in transit 
demand that cannot be accommodated by existing or proposed transit capacity, resulting in unacceptable 
levels of transit service, or cause a substantial increase in transit delay due to transit/auto conflicts. 
Regarding parking, San Francisco General Plan policies emphasize the importance of public transit use 
and discourage the provision of facilities that encourage automobile use. Therefore, the creation of, or 
increase in, parking demand resulting from a proposed project that cannot be met by existing or proposed 
parking facilities would not itself be considered a significant effect. The City has not adopted 
significance criteria for pedestrian or bicycle impacts. For this analysis, the project would have a 



This analysis is based on a Transportation Study prepared for the proposed project: Wilbur Smith Associates, San Francisco 
Southern Waterfront Supplemental EIR Transportation Study, September 22, 2000 This report is available for review at the 
San Francisco Plaiming Department, Major Environmental Analysis section, 30 Van Ness Avenue, Suite 4150, as part of 
Project File No. 1999.377E. 

The City has no significance criteria for unsignalized intersections. For this analysis, a significant effect would occur if an 
unsignalized intersection were to deteriorate such that more than one approach operates at LOS E or LOS F and the 
intersection would meet the Caltrans Minimum Vehicle Volume Warrant or Peak-Hour Warrant for signalization. 



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B. TRANSPORTATION - IMPACTS 



significant effect if it were to result in substantial pedestrian overcrowding, create particularly hazardous 
conditions for pedestrians or bicyclists, or otherwise substantially interfere with pedestrian and bicycle 
accessibility. Generally, construction-period transportation impacts would not be considered significant 
because they would be temporary. 

IMPACT ANALYSIS 

This analysis examines transportation conditions for three time frames: Existing-plus-Project, when the 
Industry Group project components would be in operation; 2003, when the Illinois Street intermodal 
bridge would be in place and the Muni Third Street light rail line is anticipated to begin operations'.^^ and 
2015, by which time the Future Port Development described in the Project Description would occur. The 
Existing-plus-Project and 2003 analyses also include some amount of future cargo shipping and other 
activity on Port lands (see "Cargo Shipping" on p. 23 of the Project Description) in order to capture 
effects of Phase I of the project, while the remainder of Future Port Development (2015) constitutes 
Phase II. For each future analysis period, additional background, or cumulative, development is also 
assumed. For 2003, partial development of the Mission Bay project, located north of the study area, is 
assumed, while full buildout of Mission Bay is assumed for 2015. Development to varying degrees is 
also assumed in connection with the redevelopment of Hunters Point shipyard and the larger Bay view- 
Hunters Point neighborhood, both of which are the subject of plans prepared by the San Francisco 
Redevelopment Agency: the Hunters Point plan is approved, while neighborhood-wide redevelopment 
plan is currently being drafted. 

Trip generation for the Industry Group project components would be primarily a function of the volume 
of construction aggregate material (concrete and, potentially, asphalt concrete) produced. (This is 
contrasted with the traffic analysis of more "typical" land uses, such as office or retail uses, for which 
trip generation is normally determined on the basis of standard per-square-foot factors.) Therefore, the 
analysis is based to a large degree on production estimates provided by the Industry Group. It should be 
noted that a substantial volume of the Phase I vehicle trips related to the Industry Group project 
components are currently being made, under existing conditions, to and from other parts of 
San Francisco. For example, delivery of concrete is made from the existing Bode Gravel Company and 
RMC Pacific Materials plants located on Third Street at 16th Street and at Mariposa Street, respectively. 
Existing delivery of asphalt concrete is made to locations in San Francisco from plants in Berkeley and 
in Brisbane. For purposes of a conservative analysis, and because these trips originate at the fringe of or 
outside the study area, no attempt was made to subtract existing trips from the roadway network, with the 
sole exception being existing trips made between Pier 92 and the concrete plants for the purpose of 
hauling sand dredged from San Francisco Bay. Other than these dredge sand trips, which currently 
originate within the study area, all trips described in the Travel Demand Analysis, below, were assigned 
to the transportation network as new trips. 



The analysis was conducted consistent with the original scliedule for the Third Street Light Rail Project, which anticipated a 
start of service in 2003. The current schedule calls for start of operations in 2004. 



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While the change in location of the production of construction aggregates would not necessarily result in 
any change in the demand for these products in San Francisco and the northern Peninsula, another factor 
was considered in the transportation analysis that would affect traffic volumes, particularly truck traffic: 
the method by which raw materials (sand, rock, cement, liquid asphalt cement) would be brought to the 
production plants. Currently, most aggregate is brought by truck from local quarries, primarily in the 
East Bay. However, one of the objectives of the Industry Group members is to relocate to sites with 
maritime access, and given that the supply of aggregate in local quarries is anticipated to decline over the 
analysis period covered in this SEIR, this analysis assumes a shift from truck to ship transportation 
would occur over time. Therefore, in the Phase I analysis, 50 percent of the aggregate material required 
for ready-mix concrete production (other than "dredge sand" that is already brought by barge from 
within San Francisco Bay) would arrive by ship at one or more of the Industry Group facilities as 
proposed in the near term by Industry Group members. (British Pacific Aggregates, Mission Valley 
Rock, and RMC Pacific Materials would all have the capability to import construction aggregates.) The 
remaining 50 percent of concrete aggregate would continue to be brought by truck from the East Bay. 
For production of asphalt concrete, which would be newly manufactured in San Francisco by Mission 
Valley Rock, all of the aggregate material would be conveyed by ship. By 2015, which is the horizon 
year for this analysis, 80 percent of the aggregate to be used in ready-mix concrete is assumed to be 
delivered by ship. Further explanation of the assumptions regarding the production of construction 
aggregate is provided in Appendix A. 

Travel Demand Analysis 

For Phase I of the project (primarily the Industry Group components), the vast majority of traffic 
generated would be truck traffic in connection with the production of construction aggregates and 
shipping activity at the Port.29 Employee traffic would make up a relatively small percentage of this 
traffic. For this analysis, truck trip generation and the assignment of those trucks to the roadway network 
(i.e., the direction of their travel) were based on information from the Industry Group. Employee trips to 
and from work were based on forecast employment at the Industry Group facilities. The means of travel 
(auto, transit, etc.) and the direction of travel was based on the standard methodology contained in the 
Planning Department's Interim Transportation Impact Analysis Guidelines for Environmental Review, 
although the percentage of employees expected to use transit was reduced by half from the typical 
percentage for the southeastern part of San Francisco (and the percentage driving increased accordingly), 
because of the relatively remote location of the project area vis-a-vis transit service and the early start 
time for many construction industry-related land uses. The resulting formulae assumed that about 
82 percent of employees would drive to work (either alone or in carpools), while about 9 percent would 
use transit, and the remaining 9 percent would use other means of travel, including walking and 
bicycling. 



The Illinois Street bridge would not generate any traffic, although it would result in redistribution of traffic with destinations 
accessible via the bridge. See the intersection level of service results in Table 4, p. 53. 



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B. TRANSPORTATION - IMPACTS 

Table 2 presents a summary of trip generation for Phase I of the project. As indicated in Table 2, the 
Industry Group project components would generate about 2,200 vehicle trips (a trip is one way; two trips 
make up a round trip) per day, of which about 1,850 would be truck trips. In the morning (a.m.) peak 
hour, the Industry Group components would generate about 480 vehicle trips, while they would generate 
about 325 vehicle trips in the afternoon (p.m.) peak hour. 

An estimated 210 additional daily vehicle trips, including about 180 truck trips, would be made to and 
from the project area by the time the Industry Group components are operational, including about 
50 a.m. peak-hour vehicle trips and about 20 p.m. peak-hour vehicle trips. These trips would be 
generated by other anticipated uses on Port land, including additional cargo shipping at Pier 96 beyond 
that currently existing and future industrial activity on the Western Pacific site. By 2003, when the 
Illinois Street bridge would be in place and the Muni Third Street light rail line would begin service, 
nearly 1,700 additional vehicle trips, including almost 1,300 truck trips, are anticipated to be made to and 
from the project area each day on Port land, including about 125 a.m. peak-hour vehicle trips and about 
110 p.m. peak-hour vehicle trips. 

By 2015, overall daily vehicle trip generation would nearly quintuple, largely as a result of future 
development that would occur on port property, including more than 1.6 million square feet of office and 
research and development space at the Pier 70 Mixed-Use Opportunity Area and the Pier 90-94 
backlands, and 100,000 square feet of retail space at the Pier 70 Mixed-Use Opportunity Area. Also 
included is more than 1 million square feet of light, general, and maritime industrial uses at Pier 70 and 
Piers 90-94. (See the discussion of Future Port Development in Chapter II, Project Description, p. 22, 
for additional discussion of these assumptions.) This future port development would generate more than 
14,000 daily vehicle trips, nearly 1,800 vehicle trips in the a.m. peak hour and more than 1,700 vehicle 
trips in the p.m. peak hour. In addition, anticipated growth in cargo shipping would increase daily 
vehicle trip generation from Port activity by nearly 50 percent (to approximately 2,450) and p.m. peak- 
hour vehicle trip generation by 55 percent (to about 170), compared to 2003 levels; a.m. peak-hour trip 
generation would more than double, compared to 2003, to approximately 265 vehicle trips. Industry 
Group truck traffic would also increase because, while the percentage of raw materials brought in by ship 
would increase, the increased production volume assumed by 2015 would result in more local truck trips 
by cement mixers and asphalt trucks making deliveries. Vehicle trip generation for 2015 is presented in 
Table 3. 

Traffic Impacts 

The traffic analysis focuses on local streets and intersections because, as noted in the discussion of 
Travel Demand, most of the traffic generated by Phase I of the project (primarily the Industry Group 
project components) would involve truck traffic between the project area and points within 
San Francisco and on the northern Peninsula. The analysis evaluated 17 intersections throughout the 



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TABLE 2 

PHASE I PROJECT VEHICLE TRIP GENERATION (NEAR TERM AND 2003) 



Trip Origin or Destination^ 


Daily Vehicle Trips 
Trucks'' Employees 


A.M. Peak Hour Trips 
Trucks'' Employees 


P.M. Peak Hour Trips 
Trucks'' Employees 


TnHiicfi'v r^i*niin 
















347 


30 


66 


7 


17 


7 


XvlVlV^ X aL-lilL' X ICl 0\J J 


347 


34 


66 


8 


17 


8 


Mission Valley Rock (Pier 92) 


213 


20 


41 


5 


11 


5 


ISO Resources (Pier 92) 


14 


18 


3 


4 





4 


British Pacific (Pier 94)^= 


14 


18 


3 


4 


1 


4 


Dredge Sand (Pier 92)'* 


(42) 


e 




e 


(2) 


e 


Pleasanton (inbound aggregate) 


144 


e 


32 


e 


8 


e 




8 


e 


2 


e 





e 


Redwood City (inbound cement) 


42 


e 


9 


e 


2 


e 


Subtotal: Aggregate Production 


1,087 


120 


212 


28 


54 


28 


Coach USA (Pier 96) 


410 


228 


157 


53 


157 

X^ / 


53 


VVaoL^ iVlallagdlldll Id 


350 


18 


27 


4 


27 


4 


Subtotal: Industry Group 


1,847 


366 


396 


85 


238 


85 


Ind. Group: All Vehicle Trips 


2,213 




481 






323 


\ e*^w\\'\i inoQi* ^ov*mi 

t on /vLiiviiy ^ncai lerm^ 














Cargo Shipping (Pier 96) 


115 


20 


25 


7 


6 


7 

/ 


Gen. Industry (Western Pacific) 


64 


12 


14 


3 


3 


3 


Subtotal: 2001 Port Activity 


179 


32 


39 


10 


9 


10 


Near Term Port Vehicle Trips 


211 




49 






19 


GRAND TOTAL - Near Term 


2,026 


398 


435 


95 


247 


95 


ALL VEHICLE TRIPS 


2,424 




530 






342 


Port Activity (2003)^ 














Cargo Shipping (Pier 80) 


64 


12 


8 


6 


4 


5 


Other Activity (Pier 96) 


1,220 


374 


87 


26 


51 


50 


Subtotal: 2003 Port Activity 


1,284 


386 


95 


32 


55 


55 


2003 Port Vehicle Trips 


1,670 




127 






110 


GRAND TOTAL - 2003 


3,310 


784 


530 


127 


302 


150 



ALL VEHICLE TRIPS 4,094 657 452 



Numbers shown are one-way trips (one round trip equals two one-way trips). Truck trips are shown by origin. 
Therefore, some trips originate outside the study area (for example, inbound raw materials). Employee vehicle 
trips are shown by location of employment (destination). 
Includes buses for Coach USA. 

For air quality analysis only, additional internal truck trips assumed from Pier 94 to RMC Pacific at Pier 80. 
Dredge sand trips include elimination of 84 existing daily trips between Pier 92 and the Bode and RMC ready- 
mix concrete plants. 

These truck trips do not result in employee trips to and from the project area. 
Additional to Near Term 



Source: Wilbur Smith Associates; Environmental Science Associates. 



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B. TRANSPORTATION - IMPACTS 



TABLE 3 

PHASE II PROJECT VEHICLE TRIP GENERATION (2015) 





Daily Vehicle Trips 


A.M. Peak Hour Trips 


P.M. Peak Hour Trips 


Trin Oritrin or Dpstination^ 


Trucks*' 


Employees 


Trucks'' 


Employees 


Trucks'' 


Employees 


Industry Group 














Bode Gravel (Pier 92) 


453 


30 


85 


7 


23 


7 


RMC Pacific (Pier 80) 


453 


34 


85 


8 


23 


8 


iviission Valley ixock ^^r icr y^j 


401 


20 


80 


5 


20 


5 


ISG Resources (Pier 92) 


36 


18 


8 


4 


2 


4 


British Pacific (Pier 94)<= 





18 





4 





4 


Dredge Sand (Pier 92)<^ 




e 




e 




e 


Pleasanton (inbound aggregate) 


81 


e 


18 


e 


4 


e 


Richmond (inbound asphalt) 


11 


e 


2 


e 


1 


e 


Redwood City (inbound cement) 


55 




12 


e 


3 


e 


Subtotal: Aggregate Production 


1,448 


120 


280 


28 


74 


28 


Coach USA (Pier 96) 


410 




1 S7 




1 '57 




Waste Management (Pier 70) 


350 


18 


27 


4 


27 


4 


Subtotal: Industry Group 


2,208 


366 


464 


85 


258 


85 


Ind. Group: All Vehicle Trips 




2,574 




549 




343 


Port Activity (2015) 














Cargo Shipping (Pier 80) 


224 


26 


28 


12 


14 


10 


Cargo Shipping (Pier 96) 


435 


38 


65 


18 


26 


12 


Gen. Industry (Western Pacific) 


128 


12 


28 


3 


6 


3 


Other Activity (Pier 96) 


1,220 


374 


87 


26 


51 


50 


Subtotal: 2015 Port Activity 


2,007 


450 


208 


59 


97 


75 



2015 Port: All Vehicle Trips 2,457 267 172 
Future Port Development*^ 

Pier 70 Maritime Reserve 1,692 203 120 

Pier 70 Mixed Use 0pp. Area 7,130 537 781 

Pier 90-94 Backlands 5,220 1,051 807 

Subtotal: Port Development 14,042 1,791 1,708 

GRAND TOTAL - 2015S 4,215 14,858 672 1,935 355 1,868 

ALL VEHICLE TRIPS 19,073 2,607 2,223 



Numbers shown are one-way trips (one round trip equals two one-way trips). Truck trips are shown by origin. 
Therefore, some trips originate outside the study area (for example, inbound raw materials). Employee vehicle 
trips are shown by location of employment (destination). 
Includes buses for Coach USA. 

For air quality analysis only, additional internal truck trips assumed from Pier 94 to RMC Pacific at Pier 80. 
Dredge sand trips include elimination of 84 existing daily trips between Pier 92 and the Bode and RMC ready- 
mix concrete plants. 

These truck trips do not result in employee trips to and from the project area. 

Truck traffic not separately calculated for these more "typical" urban land uses; trip generation column includes 
employee and visitor (non-employee) trips. 
S 2015 employee trips include visitor trips for future port development. 

SOURCE: Wilbur Smith Associates; Environmental Science Associates. 



Case No. 1999.377E 



51 

ESA 990267 



Southern Waterfront SEIR 



ni. ENVIRONMENTAL SETTING ANfD IMPACTS 



B. TRANSPORTATION - IMPACTS 



Southern Waterfront, with the focus on major routes to and from Port lands, including Third Street, 
Cesar Chavez (Army) Street, Illinois Street, and Mariposa Street. In addition, several intersections were 
examined at the gateway to much of the Industry Group activity, in the vicinity of Third Street and Cargo 
Way. The results of the traffic analysis are presented in Table 4 and are portrayed graphically in 
Figure 5, p. 55. As indicated in the table and figure, traffic generated in the near term, mostly by the 
Industry Group components, would adversely affect two intersections: morning (a.m.) peak-hour 
operations at the signalized intersection of Third Street and Cargo Way would deteriorate from Level 
of Service (LOS) B under existing conditions to LOS F, and at the signalized intersection of 25th and 
Third Streets, afternoon (p.m.) peak-hour conditions would deteriorate, also to LOS F from an existing 
LOS B. These changes would occur in the near term, by about 2001. By 2003, with all Phase I project 
traffic, including an additional increment of Port development, as well as traffic from other background 
growth in the vicinity, p.m. peak-hour conditions at Third and Cargo would also deteriorate to LOS F 
without the Illinois Street Bridge, from LOS C at present and LOS D with Existing-plus-Industry Group 
(near term) conditions. Also by 2003, a third intersection would be adversely affected: the unsignalized 
intersection of Amador Street and Cargo Way would deteriorate to LOS F in the p.m. peak hour with 
Phase I traffic and completion of the Illinois Street bridge. 

The worsening in a.m. peak-hour LOS at Third and Cargo would be caused by the heavy volume of 
Industry Group traffic from Cargo Way onto northbound Third Street. Without the Illinois Street bridge, 
this condition would worsen in 2003 as the volume of traffic on Cargo Way increases. However, with 
completion of the Illinois Street bridge, a.m. peak-hour operations at Third and Cargo would be at 
LOS C, which is acceptable, and would continue at LOS C even with additional future Port development 
by 2015, including at the Pier 90-94 backlands. In the p.m. peak-hour, the deterioration in LOS would be 
due primarily to southbound traffic tuming left from Third Street onto Cargo Way. As with a.m. 
conditions, p.m. peak-hour operations would improve with completion of the Illinois Street bridge, to 
LOS D, which is acceptable. Therefore, the Industry Group components would have an interim (short- 
term) significant effect at the intersection of Third Street and Cargo Way, which would be avoided by 
implementation of the Illinois Street bridge, which is also part of Phase I of the project. 

At 25th and Third, the deterioration in LOS would be a consequence of the increased volume of 
southbound through traffic, which would result in inadequate time for northbound left-turning vehicles to 
make that movement and consequently long delays for those left-turning vehicles. Other movements at 
this intersection would operate with acceptable delays, but the number of existing left-turning vehicles is 
such that, with additional delay caused by heavier southbound volume, the overall average delay for all 
vehicles at this intersection would be unacceptable. Two points should be noted concerning the 
intersection of 25th and Third Streets: first, the unacceptable LOS F operations would be a short-term 
phenomenon, because the traffic signal at this intersection is scheduled to receive a separate left-turn 
phase in 2003 as part of the Third Street Light Rail Project. Secondly, delays for left-turning vehicles 
might result in a self-correcting impact, in that motorists might select altemate routes with less delay. 
However, it would be speculative to conclude that the intersection would operate acceptably prior to 



Case No. 1999.377E 



52 

ESA 990267 



Southern Waterfront SEIR 



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B(C) 


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A 


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E(F) 




1 




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1-280 SB on ramp/Mariposa 


P 




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A 


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C 


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E 


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c 


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A(B) 


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A(B) 


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Francisco 
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c 


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D 


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D 


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Intersection Name 




























Signalized Intersection 
Q Unsignalized Intersection 

Unsignalized Intersection Approved for Signal 
{see text) 

•LOS reported for overall Intersection; 
LOS in parentheses is for critical movement at unsignalized 
Intersection (normally, minor street left-turn). 



SOURCE: Wilbur Smith Associates 



J999.377E: Southern Waterfront SEIR (ESA 990267) ■ 

Figure 5 

Intersection Levels of Service 



55 



III. ENVIRONMENTAL SETTING AND IMPACTS 



B. TRANSPORTATION - IMPACTS 



creation of new signal phasing; further, such changes in travel patterns could have their own - albeit 
speculative - impacts elsewhere. Therefore, Phase I of the project would have an interim (short-term) 
significant effect at the intersection of 25th and Third Streets, which would be eliminated by 
implementation of the already-approved change in signal timing as part of the Third Street Light Rail 
project. 

At Amador Street and Cargo Way, completion of the Illinois Street bridge would result in a change in 
traffic patterns such that the volume of traffic turning left from Amador Street to Cargo Way would 
increase substantially, compared to existing conditions and conditions with Industry Group traffic but 
without the bridge, in the near term and in 2003. In the p.m. peak hour, this change in traffic flow would 
result in lengthy delays that would result in the intersection operating at LOS F. (In the a.m. peak hour, 
delays would also be long for Amador Street left turns, but the volume of traffic making this movement 
would be less than in the afternoon, and overall intersection operations would remain at LOS B.) By 
2015, the addition of Phase I and Phase II project traffic, along with the Illinois Street bridge, would 
result in unacceptable LOS F conditions at this intersection in both the a.m. and p.m. peak hours. This 
would be a significant effect. However, the impact could be mitigated through installation of a traffic 
signal and restriping (see Chapter IV, Mitigation Measures, p. 144). 

At the unsignalized intersection of Mariposa Street and the Interstate 280 southbound on-ramp. 
Phase I of the project would result in increased delays during both the a.m. and p.m. peak hours. This 
intersection currently operates at LOS F during both peak hours, and Phase I project traffic would 
increase delays. This condition would continue to worsen by 2003, when additional traffic from the 
approved Mission Bay project would further increase delays. By 2015, this intersection is scheduled to 
be signalized, and the signalized intersection would operate at an acceptable LOS under 2015 No-Project 
conditions (i.e., without the Industry Group project components or future Port development).^^ 
However, the addition of Phase I and Phase II project traffic by 2015 would result in unacceptable 
conditions at this intersection, even signalized: LOS F in the a.m. peak hour and LOS E in the p.m. 
peak-hour. This would be a significant effect, and would not be mitigable, as the intersection capacity 
would be exceeded. 

The other 13 study intersections would operate at acceptable levels of service (LOS D or better) in all 
scenarios prior to 2015. 

The Illinois Street bridge would allow for removal of railroad tracks that currently run through the 
Mission Bay project area and would represent a benefit to traffic patterns in the Mission Bay area: the 
approved Mission Bay plan currently calls for the tracks that connect the Union Pacific main line to 
those on Illinois Street to be replaced with tracks in the 16th Street right-of-way. With completion of the 



Mitigation for intersection levels of service identified in the Mission Bay Subsequent EIR (Case No. 96.77 IE; Final SEIR 
certified September 17, 1998) is keyed to generation of specific volumes of traffic, and thus, based on development 
assumptions, is assumed to be in place by 2015 at the Mariposa Street / 1-280 southbound on-ramp intersection, although it 
could occur earlier. 



Case No. 1999.377E 



56 

ESA 990267 



Southern Waterfront SEIR 



in. ENVIRONMENTAL SETTING AND IMPACTS 

B. TRANSPORTATION - IMPACTS 

Illinois Street bridge, there would be no need for tracks in 16th Street, thereby eliminating a potential 
conflict between trains and vehicle traffic. 

By 2015, all intersections except Third and Cesar Chavez Streets would operate at acceptable levels of 
service under No Project conditions, accounting for background growth including traffic from the 
Hunters Point Shipyard redevelopment project, the Mission Bay project, and the Bay view-Hunters Point 
redevelopment area. The poor p.m. peak-hour LOS at Third / Cesar Chavez Streets (LOS E in the 2015 
Baseline) would result from changes in lane configuration due to the Third Street Light Rail Project and 
increased background (non-project) traffic. This impact was identified in the EIR/EIS for the Third 
Street Light Rail Project (FTA and San Francisco Planning Department, 1998). Project traffic would 
degrade this LOS to LOS F in the p.m. peak hour, and the project would result in a considerable 
contribution to a cumulative significant impact. 

The additional traffic from future Port development (Phase II of the project), along with Phase I traffic, 
would result in unacceptable conditions (LOS E or LOS F) at eight of 17 study intersections in the a.m. 
peak hour and at 10 of 17 study intersections in the p.m. peak hour. Therefore, the project would result 
in a significant effect at each of these intersections (see Table 4, which compares conditions in 2015 with 
and without project traffic). Mitigation has been identified to reduce impacts to a less-than-significant 
level at Third / 25th Streets; Illinois / 25th Streets; Pennsylvania Street / 1-280 southbound on-ramp; 
Pennsylvania / Cesar Chavez Streets; Third / Cesar Chavez Streets; and Illinois Cesar Chavez Streets, as 
well as at Amador Street / Cargo Way, as described above (see Chapter IV, Mitigation Measures, 
p. 144). Impacts at four intersections would not be mitigable. These include Mariposa Street / 1-280 
southbound on-ramp, described above; Mariposa Street / 1-280 northbound off-ramp; Third / Mariposa 
Streets; and Evans Avenue / Cesar Chavez Street. 

Of the four SEIR analysis intersections that were also studied in the Waterfront Plan EIR (Third / 
Mariposa Streets, Third / 25th Streets, Third /Cesar Chavez Streets, and Third Street / Evans Avenue), 
levels of service at all but Third / Evans would be worse in the p.m. peak hour in 2015 (a.m. peak hour 
was not analyzed), based on the present analysis, than was projected for 2010 in the Waterfront Plan 
EIR. Third / Mariposa and Third / 25th Streets were both projected to operate at LOS B in 2010, while 
Third / Cesar Chavez was projected to operate at LOS D in 2010. Compared to the 2015 levels of 
service projected in the Third Street Light Rail EIR/EIS, the LOS identified in the present analysis would 
be worse at Third / Mariposa in both the a.m. and p.m. peak hours (LOS E vs. LOS D, a.m.; and LOS E 
vs. LOS C, p.m.), while at Third / Cesar Chavez, the current analysis shows a deterioration in the a.m. 
(LOS F vs. LOS D), but the same level of service (LOS F) in the p.m. (These are the only two 
intersections shared by this SEIR and the Third Street Light Rail EIR/EIS.) 

Transit 

As noted in the discussion of Travel Demand, above, approximately 9 percent of employee trips to work 
for Phase I of the project (primarily the Industry Group components) are anticipated to be made using 
transit, which is half the percentage typically assumed for southeastern San Francisco. This is because 



Case No. 1 999. 3 77 E 



57 

ESA 990267 



Southern Waterfront SEIR 



III. ENVIRONMENTAL SETTING AND IMPACTS 

B. TRANSPORTATION - IMPACTS 

transit access to the Industry Group sites is currently limited, and many workers would be expected to 
begin and end their work days prior to more typical work hours. Furthermore, the number of peak-hour 
trips would be less for Phase I than for typical land uses, because many of the Industry Group employees 
in construction- and aggregate-related industries normally begin work by about 7:00 a.m. and finish work 
by about 3:30 p.m. As a result. Phase I would generate fewer than 25 transit trips in the a.m. and p.m. 
peak hours. These new transit riders would represent a very small increase over existing ridership in the 
area, and would not result in a significant effect. 

Phase II of the project includes additional growth in cargo shipping and related activities at Pier 70 (the 
maritime reserve area). Pier 80, and Piers 94-96, as well as development of non-maritime and non- 
industrial uses at the Pier 70 Mixed-Use Opportunity Area and the Piers 90-94 backlands. The Mixed- 
Use Opportunity Area and the backlands together would include 1 .6 million square feet of office and/or 
research and development space and 100,000 square feet of retail space, which would have trip 
generation characteristics such that transit use among commuters and visitors would likely be greater 
than that assumed for the maritime and industrial uses elsewhere in the project area. Table 5 presents 
estimated transit ridership for Phase II of the project. Of the estimated approximately 680 a.m. peak- 
hour and 625 p.m. peak-hour transit trips, afeout 80 percent would be made in the peak direction (to the 
work place in the morning and from the work place in the afternoon). 

The increase in transit ridership by 2015, along with growth in ridership due to other development in the 
project area and elsewhere, could be accommodated by Muni routes serving the project area. On the 
Third Street Light Rail line, the percent of p.m. peak-hour, peak-direction transit vehicle capacity used 
("capacity utilization") would be 83 percent in the p.m. peak hour. The project would add about 450 new 
riders, and increasing capacity utilization from 45 percent (with cumulative growth but without the 
project) to 83 percent with the project. Because adequate capacity would remain, the effect would not be 
significant. Peak-direction capacity utilization on the three principal bus lines that serve the project area 
(19-Polk, 22-Fillmore, and 48-24th Street/Quintara Avenue) would be between 90 percent and 
100 percent. Only the 22-Fillmore would operate at capacity; however, project ridership would amount 
to only 6 trips, and would not result in a significant effect. Project ridership on the other lines would be 
40 trips or less; adequate capacity would remain on all lines and the project impact would not be 
significant. 

Project ridership by 2015 on regional transit carriers would total about 95 p.m. peak-hour trips to the East 
Bay (85 on BART, 10 on AC Transit); about 80 p.m. peak-hour trips to the Peninsula and South Bay (50 
on Caltrain, 30 on BART); and about 15 p.m. peak-hour trips to the North Bay on Golden Gate buses and 
ferries. Both BART (to the East Bay) and AC Transit would operate in excess of capacity, although 
BART trains would remain within the system's standard of 1 15 percent for the three-hour peak period. 
Project-generated ridership would increase BART capacity utilization by less than 0.5 percent, and AC 
Transit capacity utilization by less than 0.3 percent, and therefore would not result in a significant 
impact, because the contribution to cumulative overcrowding would be negligible. 



Case No. 1999.377E 



58 

ESA 990267 



Southern Waterfront SEIR 



III. ENVIRONMENTAL SETTING AND IMPACTS 
B. TRANSPORTATION - IMPACTS 



TABLE 5 

PHASE II PROJECT TRANSIT TRIP GENERATION (2015) 



Transit Trips 



Location 


Uses 


Size 


Daily 


AMPkHr 


PMPkHr 


Pier 70 Mixed Use 


Wince / Kocu 


oiu,uuu SCJ. It. 




148 


1 


Opportunity Area 


Retail/Commercial 


100,000 sq. ft. 


1,467 


47 


122 


Pier 70 Maritime 


Maritime Industry 


200,000 sq. ft. 


405 


49 


13 


Reserve 














General Industry 


200,000 sq. ft. 


312 


37 


38 


Pier 90-94 Backlands 


Light Industry 


650,000 sq. ft. 


1,311 


158 


42 




Office /R&D 


1 million sq. ft. 


1,754 


242 


256 


Total 






6,259 


681 


626 



SOURCE: Wilbur Smith Associates 



Increased traffic congestion on Third Street and at local intersections would be expected to result in some 
increased delay for transit vehicles traveling in the study area. However, because light rail vehicles 
would travel in a dedicated right-of-way, delays on Third Street would be limited to those locations 
where left-turning cars could interfere with light rail vehicles. Additional conflicts could occur in 
connection with use of the Muni light rail loop track at Third/ 18th/Illinois Streets. However, use of this 
loop is not anticipated until substantial buildout has occurred at the Mission Bay project area, when 
demand for additional light rail service between Mission Bay and downtown will likely be required. 

Parking and Loading 

For the Industry Group project components in Phase I of the project, the parking demand would be 
limited almost entirely to employee vehicles. Each of the Industry Group sponsors has indicated plans to 
provide for on-site employee parking. Because the Industry Group components would include large flat 
areas, no lack of parking supply is anticipated, even though, as noted above under Travel Demand, this 
analysis assumes that a greater share of employees would drive than is typically assumed in this part of 
San Francisco, because of the current relative lack of transit service in the area and the early start time 
for many construction industry-related land uses. The Planning Code parking requirement is normally 
calculated on the basis of occupied floor area within building(s) on a site. Because most of the Industry 
Group uses would involve primarily open yards and equipment, the requirement would be minimal if 
calculated in this manner. A similar situation would arise with respect to open areas used for cargo 
shipping (Piers 80 and 94-96) and outdoor industrial uses (potentially the Western Pacific site under 
future port development). The Phase I components would be mostly related to handling of construction 
materials, and these facilities therefore would be established to accommodate the loading and unloading 



Case No. 1 999. 3 77 E 



59 

ESA 990267 



Southern Waterfront SEIR 



m. ENVIRONMENTAL SETTING AND IMPACTS 



B. TRANSPORTATION - IMPACTS 



of these materials. However, there would not be expected to be much in the way of more typical loading 
activity that is associated with commercial buildings. 

Future Port development in Phase II of the project would involve development of more conventional land 
uses, compared to the Phase I components. In particular, the development of more than 1.6 million 
square feet of office and research and development space at the Pier 70 Mixed-Use Opportunity Area and 
the Pier 90-94 backlands would result in an estimated demand for nearly 3,300 parking spaces, or about 
two-thirds of the parking demand for Phase II of the project. Estimated parking demand and Planning 
Code parking requirements are presented in Table 6. Actual parking demand and requirements could 
vary by use and by site, depending on the actual uses that are proposed in the future on Port property. It 
is assumed that the relative lack of site constraints (i.e., the availability of large development sites) 
would facilitate the provision of both adequate parking and off-street loading space for individual 
projects, meaning that no significant effects would be expected. It is also assumed that large projects 
that may be proposed would be subject to detailed transportation analyses. 

Pedestrian and Bicycle Conditions 

Phase I project components (primarily those of the Industry Group) would generate little in the way of 
pedestrian or bicycle traffic (see discussion under Travel Demand, above), so the potential effects of the 
project would be largely those of increased truck traffic on existing pedestrians and bicycles. Neither 
pedestrian nor bicycle traffic is noticeable in the immediate vicinity of most of the Industry Group 
projects (i.e., along Amador Street, 20th Street, Cesar Chavez Street, and other streets east of Illinois 
Street). Thus impacts would be limited in the immediate area. Pedestrian traffic elsewhere in the greater 
project area (e.g., on Third Street, Illinois Street,^! and most east-west streets west of Illinois Street) 
travels on sidewalks that separate pedestrian traffic from trucks and other vehicles, and these sidewalks 
would remain in the future, meaning that impacts would be minimal because pedestrians would continue 
to have separate rights-of-way. Furthermore, the heaviest concentrations of added truck traffic would be 
in areas with little pedestrian activity. It should also be noted that much of the project area east of 
Illinois Street is, and will continue to be, a heavy industrial area. Indeed, most of the proposed Industry 
Group components, including concrete ready-mix plants, aggregate materials import and storage, and, 
potentially, asphalt batch plant(s), are not pedestrian-friendly, in the sense that the movement of heavy 
materials, high volumes of truck traffic, and noise and dust in the immediate area are not conducive to 
leisure walking. Therefore, the provision of pedestrian access for casual walkers is not necessarily the 
public benefit it would be in areas of the waterfront north of Pier 70. 

The project would not adversely affect pedestrian access to the Bay Trail, which is designated on Illinois 
Street north of 24th Street and on Third Street south of 24th Street. Existing sidewalks on these streets 
would remain in place and would continue to function as part of the Bay Trail. 



Some parts of Illinois Street that are currently unimproved will receive sidewalks in the future, independent of the project, 
including between 25th and Cesar Chavez Streets, where the street would be paved and sidewalks as part of the construction 
of the Third Street light rail service yard at the Western Pacific site. 



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TABLE 6 

PHASE II PARKING DEMAND AND REQUIREMENT (2015) 









Parking Demand 


Parking 


Location 


Uses 


Size 


Empl. 


Visitor 


Total 


Req't.^ 


Pier 70 Mixed Use 


Office / R&D 


610,000 sq. ft. 


1,127 


112 


1,239 


1,098 


Opportunity Area 


Retail/Commercial 


100,000 sq. ft. 


155 


307 


462 


320 


Pier 70 Maritime 


Maritime Industry 


200,000 sq. ft. 


191 


27 


218 


120 


Reserve 


General Industry 


200,000 sq. ft. 


191 


21 


212 


120 


Pier 90-94 Backlands 


Light Industry 


650,000 sq. ft. 


622 


88 


710 


390 




Office / R&D 


1 million sq. ft. 


1,848 


183 


2,031 


1,800 


Total 






4,134 


738 


4,872 


3,848 



^ Estimated Planning Code parking requirement. 
Source: Wilbur Smith Associates 



Existing bicycle traffic travels in shared lanes with automobile and truck traffic, and increased traffic 
volumes, particularly on Third Street, could create more potential for conflict between motor vehicles 
and bicycles. This would be particularly true in 2003 and thereafter, when Third Street will be reduced 
from three to two travel lanes in each direction due to operation of the Muni Third Street light rail line. 
Although the San Francisco Bicycle Plan recommends striping of bicycle lanes on Third Street, the loss 
of one traffic lane in each direction to provide for light rail tracks has precluded the creation of these 
bicycle lanes (FTA and San Francisco Planning Department, 1998, p. 3-69). Alternative routes are 
available in portions of the study area, including Indiana Street (Route 7, north of Cesar Chavez Street), 
Keith-Palou-Phelps Streets and Evans Avenue (Routes 7 and 68, south of Cesar Chavez Street), and 
Cesar Chavez Street (Route 60), which has an existing bicycle lane linking Evans Avenue and Indiana 
Street. The Department of Parking and Traffic is also considering a bicycle route on Illinois Street. 
Although traffic volumes would increase with the project, and there would a potential for increased 
conflict between bicycles and motor vehicles, as occurs elsewhere in San Francisco, the impact would 
not be considered significant because bicycle traffic could be accommodated on the variety of bicycle 
routes that are available through the project area. 

The Illinois Street bridge would provide an alternative route to Third Street for bicyclists, connecting 
Illinois Street and Cargo Way, portions of which are each part of the Bay Trail route. 

By 2015, with implementation of Phase II of the project (future Port development, including increased 
cargo shipping), traffic volumes would increase further, and pedestrian and bicycle use in the project 
area would also be anticipated to increase, particularly if mixed-use development occurs as planned at 
Pier 70 and at the Pier 90-94 backlands. Development of these mixed-use projects would be reviewed by 
the Port to ensure that adequate pedestrian access is provided, potentially including construction of 



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sidewalks where none exist on the perimeter of the development sites, and would also be required to 
include bicycle parking in accordance with the requirements in the Planning Code. Thus, pedestrian and 
bicycle conditions would be improved from conditions at present. 

Construction Impacts 

Several of the Industry Group project components would likely be under construction at the same time, 
beginning in early 2001. However, as interim facilities without permanent structures, mostly developed 
on already paved land, these components would not generate substantial or lengthy construction impacts. 
Effects on local traffic would be considerably less extensive than those described for the Phase I project 
itself, because the volume of construction-related traffic would be much less than the traffic volumes 
once all Industry Group components were operational. Further, to the extent that construction were to 
result in any traffic disruption, the effects would be largely limited to other project components or to 
operations at the Port's existing Pier 80 cargo terminal. Because most of the Phase I components would 
be developed within six months and because the effects would be mostly limited to the project area, no 
significant effects are anticipated. 

Development of the Phase II project components, including future Port development of the Pier 70 
Mixed-Use Opportunity Area and the Piers 90-94 Backlands, could result in temporary construction- 
period impacts much like those of typical urban development, but would not be considered significant. 
Effects could be limited by coordination between developers and construction contractors of projects that 
might be under development simultaneously; by avoiding off-site materials storage; and by limiting 
construction truck traffic, to the extent feasible, to between 9:00 a.m. and 3:30 p.m., or other hours as 
approved by the Department of Parking and Traffic (DPT). In addition, any lane closures for 
construction would require approval by DPT, which could limit such closures to non-peak hours. 
Because neither the Pier 70 nor Piers 90-94 areas are developed to a great extent and each includes large 
areas of open space, lane closures and sidewalk closures would probably not be required, and 
construction impacts would be largely limited to any effects that may be caused by truck traffic. 
Construction worker parking could also be accommodated on site. Therefore, construction impacts 
would be temporary and would not be significant. 



REFERENCES - Transportation 

FTA (Federal Transportation Administration) and San Francisco Planning Department, Third Street 
Light Rail Project Final Environmental Impact Statement / Environmental Impact Report, 
November 1998 (Case No. 96.281E; SCH #96102097). 



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C. AIR QUALITY 

The subject of air quality relates to ambient concentrations of pollutants in the atmosphere. This section 
translates the expected changes within the Southern Waterfront area (described in the project description) 
into the language of air quality assessment, namely "emissions" and "concentrations." "Emissions" 
estimates relay information in terms of quantities of a given pollutant per unit of time. Typically, 
emissions are reported in units of grams per second, pounds per day or tons per year. "Concentration" 
estimates relay information in terms of quantities of a given pollutant in a given volume of air. 
Typically, concentrations are reported in parts per million (by volume) or micrograms per cubic meter. 
Emissions estimates themselves cannot be directly compared to ambient air quality standards but rather 
provide only a rough indication of the relative contribution of a source to ambient concentrations. 
Concentration estimates, on the other hand, can be directly compared to ambient air quality standards. 
Ambient air quality standards represent concentrations of air pollutants below which public health and 
welfare are protected. The Waterfront Plan FEIR addressed "air quality" as one of the environmental 
conditions affected by development on Port lands, including the Southern Waterfront subarea. The 
following section updates this information and expands upon the analysis presented in the prior EIR with 
respect to the Southern Waterfront subarea. 

SETTING 
INTRODUCTION 

Air quality is a function of both the rate and location of pollutant emissions under the influence of 
meteorological conditions, and of topographic features. Atmospheric conditions such as wind speed, 
wind direction, and air temperature gradients interact with the physical features of the landscape to 
determine the movement and dispersal of air pollutants, and consequently affect air quality. This section 
addresses issues related to the two principal categories of air pollutants: "criteria air pollutants" and 
"toxic air contaminants." The term, "criteria air pollutants," refers to those pollutants that are pervasive 
in urban environments and for which state and national health-based ambient air quality standards have 
been established. The term, "toxic air contaminants," refers to those pollutants that are associated with 
carcinogenic and other adverse health effects, but occur at relatively lower concentrations than do criteria 
pollutants and have no established ambient air quality standards that are comparable to those used for 
criteria pollutants. Instead, emissions are evaluated to determine the degree to which they may increase 
health risks; there are state standards established for some air toxics, called Reference Exposure Levels 
(RELs), which are defined as concentrations at or below which no adverse health effects are anticipated 
for a specified exposure period to a specific pollutant. This setting section provides an overview of the 
regulatory context followed by region-specific information related to climate and topography; plans, 
policies, and regulations; and existing air quality conditions. 



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CLIMATE AND METEOROLOGY 

The project area lies within the City and County of San Francisco, which lies at the northern end of the 
peninsula climatological subregion of the San Francisco Bay Area Air Basin (Bay Area). The peninsula 
climatological subregion extends from northwest of San Jose to the Golden Gate. The Santa Cruz 
Mountains extend through the center of the peninsula, with elevations exceeding 2,000 feet at the 
southern end, decreasing to 500 feet in South San Francisco. Because most of San Francisco's 
topography is below 200 feet, marine air is able to flow easily across most of the City, making its climate 
cool and windy. Pollutant emissions in San Francisco are high, especially from motor vehicle 
congestion. Localized pollutants, such as carbon monoxide, can build up in "urban canyons"; however, 
winds in San Francisco are generally strong enough to carry the pollutants away from the City before 
they can accumulate (Bay Area Air Quality Management District, 1999). 

Within San Francisco, winds are generally from the west, although wind patterns are often influenced 
greatly by local topographic features. In the project area, winds generally blow out of the west- 
southwest, west, and west-northwest (Environmental Science Associates, 1998). Figure 6 shows a "wind 
rose" plot for the project area. The data that are represented in Figure 6 were collected at a location 
within the project area between Piers 70 and 72 and are representative of typical wind conditions within 
the greater project vicinity. The wind rose plot is a graphical description of wind measurements taken 
over an entire year. The bars on the figure show winds for 16 wind direction sectors spread around the 
entire 360 degree circle. The lengths of the bars indicate the fraction of time over a year that winds blow 
from that given direction. The various symbols on the bars represent the fraction of time that winds in a 
sector are blowing at the designated speed. The figure shows that winds blowing from the south 
clockwise through northwest account for approximately 67 percent of all observations in the project 
area. Winds from these directions carry pollutants released from the project site out over the Bay and not 
on the land area surrounding the site. Average wind speeds observed at the power plant are 
approximately eight miles per hour. 

REGULATORY CONTEXT 
Criteria Air Pollutants 

Regulation of air pollution is achieved through both national and state ambient air quality standards and 
emissions limits for individual sources of air pollutants. The federal Clean Air Act requires the U.S. 
Environmental Protection Agency (U.S. EPA) to identify National Ambient Air Quality Standards 
(national standards) to protect public health and welfare. National standards have been established for 
ozone, carbon monoxide, nitrogen dioxide, sulfur dioxide, particulate matter, and lead. These pollutants 
are called "criteria" air pollutants because standards have been established for each of them to meet 
specific public health and welfare criteria. California has adopted more stringent ambient air quality 
standards for most of the criteria air pollutants (referred to as State Ambient Air Quality Standards or 
State standards). Table 7 presents both sets of ambient air quality standards (i.e., national and state) and 
provides a brief discussion of the related health effects and principal sources for each pollutant. 



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1-3 4-6 7-10 11-16 17-21 +21 
Wind Speed Class (knots) 



Plot shows direction winds are blowing from. 

1999.377E: Southern Waterfront SEIR {ESA 990267) ■ 

Figure 6 

Annual Wind Rose 
Potrero Power Plant (1991-92) 



III. ENVIRONMENTAL SETTING AND IMPACTS 



C. AIR QUALITY - SETTING 



TABLE 7 

STATE AND NATIONAL CRITERIA AIR POLLUTANT STANDARDS, EFFECTS, AND SOURCES 



Pollutant 


Averaging 
Time 


State 
Standard 


National 
Standard 


Pollutant Health and 
Atmospheric Effects 


Major Pollutant Sources 


Ozone 


1 hour 
8 hours 


0.09 ppm 


0.12 ppm 
0.08 ppm ^ 


High concentrations can directly 
affect lungs, causing irritation. 
Long-term exposure may cause 
damage to lung tissue. 


Formed when reactive organic 
gases (ROG) and nitrogen oxides 
(NOjj) react in the presence of 
sunlight. Major sources include 
on-road motor vehicles, solvent 
evaporation, and commercial / 
industrial mobile equipment. 


Carbon 
Monoxide 


1 hour 
8 hours 


20 ppm 
9.0 ppm 


35 ppm 
9 ppm 


Classified as a chemical 
asphyxiant, carbon monoxide 
interferes with the transfer of fresh 
oxygen to the blood and deprives 
sensitive tissues of oxygen. 


Internal combustion engines, 
primarily gasoline-powered motor 
vehicles. 


Nitrogen 
Dioxide 


1 hour 
Annual Avg. 


0.25 ppm 


0.053 ppm 


Irritating to eyes and respiratory 
tract. Colors atmosphere reddish- 
brown. 


Motor vehicles, petroleum 
refining operations, industrial 
sources, aircraft, ships, and 
railroads. 


Sulfur 
Dioxide 


1 hour 
3 hours 
24 hours 
Annual Avg. 


0.25 ppm 
0.04 ppm 


0.5 ppm 
0.14 ppm 
0.03 ppm 


Irritates upper respiratory tract; 
injurious to lung tissue. Can 
yellow the leaves of plants, 
destructive to marble, iron, and 
steel. Limits visibility and reduces 
sunlight. 


Fuel combustion, chemical plants, 
sulfiir recovery plants, and metal 
processing. 


Respirable 
Particulate 
Matter 
(PM-10) 


24 hours 
Annual Avg. 


50 Mg/m^ 
30 |ig/m 


150|ig/m^ 
50 [ig/TxT 


May irritate eyes and respiratory 
tract. Decreases in lung capacity. 
Increased cancer and mortality. 
Produces haze and limits 
visibility. 


Dust and fume-producing 
industrial and agricultural 
operations, combustion, 
atmospheric photochemical 
reactions, and natural activities 

(p V winH-rfli^pd flii^t snH nrp^n 

sprays). 


Fine 

Particulate 
Matter 
(PM-2.5) * 


24 hours 
Annual Avg. 


— 


65 }Jg/m 
15 jig/m^ 


Increases respiratory disease, lung 
damage, cancer, and premature 
death. Reduces visibility and 
results in surface soiling. 


Fuel combustion in motor 
vehicles, equipment, and 
industrial sources. Also, formed 
from photochemical reactions of 
other pollutants, including ROG, 
NOj^, and sulfur oxides. 


Lead 


Monthly 
Quarterly 


1.5 ng/m"^ 


1.5 iig/n? 


Disturbs gastrointestinal system, 
and causes anemia, kidney 
disease, and neuromuscular and 
neurologic dysfunction. 


Present source: lead smelters, 
battery manufacturing & recycling 
facilities. Past source: combustion 
of leaded gasoline. 



NOTE: ppm = parts per million; jig/m = micrograms per cubic meter. 



On May 14, 1999, a three-judge panel of the U.S. Court of Appeals for the District of Columbia set aside the new 
national eight-hour ozone and PM-2.5 standards that U.S. EPA had issued in 1997. Essentially, the court left the new 
standards in place but put a hold on implementing the eight-hour ozone standard and asked for further comments on 
the PM-2.5 standard. This decision has been appealed to the U.S. Supreme Court. 

SOURCE: Environmental Science Associates. 



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Under amendments to the federal Clean Air Act, U.S. EPA has classified air basins, or portions thereof, 
as either "attainment" or "nonattainment" for each criteria air pollutant, based on whether or not the 
national standards have been achieved. In 1988, the State Legislature passed the California Clean Air 
Act, which is patterned after the federal Clean Air Act to the extent that areas are required to be 
designated as "attainment" or "nonattainment," but for the state standards, rather than the national 
standards. Thus, areas in California have two sets of attainment / nonattainment designations: one set 
with respect to the national standards and one set with respect to the state standards. The Bay Area is 
currently designated "nonattainment" for state and national ozone standards and nonattainment for the 
state PM-10 standard (California Air Resources Board, 1999). The urbanized portion of the Bay Area is 
also designated as a "maintenance" area for the national carbon monoxide standard. The "maintenance" 
designation denotes that the area, now "attainment," had once been designated as "nonattainment." The 
Bay Area is "attainment" or "unclassified" with respect to the other ambient air quality standards. 

The federal Clean Air Act also requires nonattainment and maintenance areas to prepare air quality plans 
that include strategies for achieving attainment. Air quality plans developed to meet federal 
requirements are referred to as State Implementation Plans (SIPs). The state Califomia Clean Air Act 
also requires plans for nonattainment areas with respect to the state standards (not including state PM-10 
nonattainment areas). Thus, just as areas in Califomia have two sets of designations, many also have two 
sets of air quality plans: one to meet federal requirements relative to the national standards and another to 
meet state requirements relative to the state standards. Such plans are to include strategies for attaining 
or maintaining the standards. 

There are currently four applicable air quality plans for the Bay Area: two related to the national ozone 
standard, one related to the state ozone standard, and one related to the national carbon monoxide 
standard. These plans include the Ozone Attainment Plan for the 1-Hour National Ozone Standard 
(Association of Bay Area Governments (ABAC), 1999), which was developed to meet federal ozone air 
quality planning requirements and which, when approved by U.S. EPA, will replace the current ozone 
SIP, the Ozone Maintenance Plan (ABAG, 1994a). The Bay Area '97 Clean Air Plan (Bay Area Air 
Quality Management District, 1997) was developed to meet planning requirements related to the state 
ozone standard. The Carbon Monoxide Maintenance Plan (ABAG, 1994b) was developed to ensure 
continued attainment of the national carbon monoxide standard. 

The Bay Area '97 Clean Air Plan represents the second triennial update of the first air quality plan 
(1991) that was developed to meet the requirements of the Califomia Clean Air Act, and it builds upon 
the control measures outlined in the previous plans. None of the new control measures identified in the 
Bay Area '97 Clean Air Plan specifically relate to the types of maritime/industrial activities associated 
with Port lands. 

Toxic Air Contaminants 

Toxic air contaminants are less pervasive in the urban atmosphere than the criteria air pollutants, but are 
linked to short-term (acute) or long-term (chronic ^nd/or carcinogenic) adverse human health effects. 



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There are hundreds of different types of toxic air contaminants, with varying degrees of toxicity. 
Sources of toxic air contaminants include industrial processes, commercial operations (e.g., gasoline 
stations and dry cleaners), and motor vehicle exhaust. Unlike regulations concerning criteria air 
pollutants, there are no regulatory standards for toxic air contaminants based on the volume of emissions. 
Instead, emissions of toxic air contaminants are evaluated based on the degree of health risk that could 
result from exposure to these pollutants. 

In particular, for toxic air contaminants linked to potential increases in cancer due to long-term exposure, 
the measurement of risk is generally calculated based on exposure over many years (e.g., 8 hours per day 
over 40 years for workers; continuous exposure over 70 years for residents), and is typically reported as 
an additional number of cancer cases, compared to the risk that would exist without exposure to the 
pollutant in question. This risk is reported as n chance in 1 million (or n cases per 1 million persons), 
where n is the number of additional cases of cancer, per 1 million individuals over a lifetime (70-year) 
exposure, that could be expected due to the pollutant in question. Typically, the reported risk level 
corresponds to the location, referred to as the "maximally exposed individual (MEI)," where the highest 
calculated risk from toxic air contaminants from a facility would occur. Risks from toxic air 
contaminants diminish at locations that are further from the facility than the MEI. 

Toxic air contaminants are regulated under the 1977 federal Clean Air Act Amendments. The most 
recent federal Clean Air Act Amendments (1990) reflect a technology-based approach for reducing toxic 
air contaminants. The first phase involves requiring facilities to install Maximum Achievable Control 
Technology (MACT). The MACT standards vary depending on the type of emitting source. U.S. EPA 
has established MACT standards for more than 57 facilities or activities, such as perchloroethylene dry 
cleaning and petroleum refineries, as of the end of year 1999. The second phase of control involves 
determining the residual health risk represented by air toxics emissions sources after implementation of 
MACT standards. 

Two principal laws provide the foundation for state regulation of toxic air contaminants from stationary 
sources. In 1983, the State Legislature adopted Assembly Bill 1807, which established a process for 
identifying toxic air contaminants and providing the authority for developing retrofit air toxics control 
measures on a statewide basis. The current list of toxic air contaminants includes approximately 
200 compounds, including all of the toxics identified under federal law plus additional compounds, such 
as particulate emissions from diesel-fueled engines, which was added in 1998. Air toxics from stationary 
sources in California are also regulated under Assembly Bill 2588, the Air Toxics "Hot Spots" 
Information and Assessment Act of 1987. Under Assembly Bill 2588, toxic air contaminant emissions 
from individual facilities are quantified and prioritized by the regional air quality management district or 
county air pollution control district. High priority facilities are required to perform a health risk 
assessment, and if specific thresholds are violated, they are required to communicate the results to the 
public in the form of notices and public meetings. Depending on the risk level, emitting facilities can be 
required to implement varying levels of risk reduction measures. 



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Regulatory Agencies 

U.S. EPA is responsible for implementing the myriad programs established under the federal Clean Air 
Act, such as establishing and reviewing the national ambient air quality standards and judging the 
adequacy of State Implementation Plans, but has delegated the authority to implement many of the 
federal programs to the states while retaining an oversight role to ensure that the programs continue to be 
implemented. California Air Resources Board (CARB), the State's air quality management agency, is 
responsible for establishing and reviewing the state ambient air quality standards, compiling the 
California State Implementation Plan and securing approval of that plan from U.S. EPA, and identifying 
toxic air contaminants. CARB also oversees the activities of air quality management districts, which are 
organized at the county or regional level. As a general matter, U.S. EPA and CARB regulate emissions 
from mobile sources and the air districts (e.g., the Bay Area Air Quality Management District) regulate 
emissions from stationary sources associated with industrial and conunercial activities. 

Criteria Air Pollutants 
Mobile Emissions Sources 

Generally, U.S. EPA and the CARB do not regulate mobile sources of air pollutants through individual 
permits but rather through emissions standards enforced on engine and vehicle manufacturers, through 
fuel specifications, and through vehicle inspection and maintenance programs. The emissions standards 
and inspection / maintenance (i.e., smog check) program for gasoline-powered automobiles are well- 
known, but standards and programs have also been established for most diesel-powered vehicles, 
including heavy trucks. 

On-road heavy-duty diesel truck emissions were first regulated by the State of California in 1969, and by 
U.S. EPA in 1974. Over the years, more stringent emission standards have paralleled improvements in 
control technology. Diesel emissions standards for trucks focus on reducing ozone precursors [i.e., 
reactive organic gases (ROG) and nitrogen oxides (NO^^)] and PM-10. The current set of emissions 
standards for reducing ozone precursors from on-road, diesel-powered vehicles took effect beginning 
with the 1984 model year, and increasingly stringent standards are being phased in through the 2004 
model year. By 2004, the emission standard for new heavy-duty diesel vehicles will be an aggregate of 
2.4 grams of NO^ and ROG, combined, per brake horsepower-hour or an aggregate of 2.5 grams of NO^^ 
and ROG, combined, per horsepower-hour with a 0.5 gram per horsepower-hour ROG cap. The current 
set of emissions standards for reducing PM-10 from on-road, diesel-powered vehicles took effect 
beginning in 1982 and increasingly stringent standards were phased in through the 1996 model year, 
which means that all new diesel equipment must meet the PM-10 emissions standard corresponding to 
the 1996 model year. New heavy-duty diesel engines today emit approximately one-third of the ozone 
precursors and one-tenth of the particulate matter compared to engines manufactured in the early 1970s 
(California Air Resources Board, 1998a). 

Emissions from diesel-powered vehicles have also been reduced by modifying the formulation of diesel 
fuel itself. Beginning in 1993, all diesel fuel sold ^pr on-road motor vehicles in California must meet 



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certain specifications (e.g., low sulfur and low aromatic content) established by CARB. "California 
diesel" provides a 7 percent reduction in NO^ and a 25 percent reduction in PM-10 relative to 
conventional diesel fuel. Off-road diesel-powered vehicles and equipment are not required to use 
"California diesel." Lastly, in 1998, CARB initiated enforcement of its roadside heavy-duty vehicle 
inspection program and began implementation of its fleet inspection program, referred to as the Periodic 
Smoke Inspection Program. The former program had been voluntary until 1998 when the program 
became mandatory. Under the latter program, California-based fleet owners, like some of the members 
of the Industry Group such as Bode Gravel Company and RMC Pacific Materials, are required to 
perform annual smoke tests on their heavy-duty vehicles. The purposes of both programs is to reduce 
excessive smoke from heavy-duty vehicles that travel on California streets and highways. (See below 
under "Toxic Air Contaminants" for information on U.S. EPA and CARB efforts to reduce TACs from 
diesel engines.) 

Unlike autos and trucks, over which U.S. EPA and CARB share regulatory authority, U.S. EPA has 
exclusive authority to establish emission standards for marine vessels and locomotives. Until recently, 
emissions associated with marine vessels and locomotives have been largely unregulated. However, in 
1999, U.S. EPA issued a final rule that establishes emissions standards for large, commercial, marine, 
diesel engines used in the United States (U.S. Environmental Protection Agency, 1999). These standards 
take effect for new engines manufactured starting in 2004, 2005, or 2007, depending upon their size. 
U.S. EPA estimates that implementation of the new standards will lead to a 24 percent reduction in 
emissions of NO^ and a 12 percent reduction in emissions of particulate matter by 2030 when the 
program is fully phased in. With respect to locomotives, U.S. EPA established emissions-related 
requirements for newly manufactured and remanufactured locomotives and locomotive engines in 1998 
(U.S. Environmental Protection Agency, 1998). These new requirements are expected to achieve an 
approximate 45 percent reduction in NOx emissions and an approximate 20 percent reduction in ROG 
and particulate matter emissions from locomotives by year 2015. 

Stationary Emissions Sources 

In the Bay Area, the Bay Area Air Quality Management District (BAAQMD) is the regional agency 
empowered to regulate air pollutant emissions from stationary sources. BAAQMD regulates air quality 
through its permit authority over most types of stationary emission sources and through its planning and 
review activities. BAAQMD permit authority would extend to many of the stationary emissions sources 
that would be operated under this project, including concrete and asphalt plants. To secure a BAAQMD 
permit, many new sources must be equipped with Best Available Control Technology (B ACT) to control 
emissions, and in some cases, must provide emissions credits to offset residual emissions increases. ^2 As 



BAAQMD will most likely be providing emissions reductions credits (offsets) from its bank for some of the permits 
associated with the Industry Group. However, these offsets have been ignored for impact evaluation purposes for this SEIR. 
That is, no credit for them has been included in the emissions tables provided in the impact discussion. 



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a general matter, BAAQMD's permit authority, does not extend to on-road motor vehicles, such as 
automobiles and trucks,^^ or to certain other types of mobile sources, such as locomotives. 

Toxic Air Contaminants 
Mobile Emissions Sources 

The regulatory approach for toxic air contaminants differs between mobile sources and stationary 
sources. Toxic air contaminants from mobile sources have been generally regulated through 
establishment (by U.S. EPA and CARB) of emissions standards for motor vehicles (imposed on vehicle 
manufacturers), and through specifications for gasoline and diesel fuel sold in California (imposed on 
fuel refineries and retailers), rather than through air quality permits or regulations on how motor vehicles 
are used by the general public. As described above for criteria air pollutants (mobile emissions sources), 
the CARB has already adopted control measures which reduce particulate matter emissions from diesel- 
fueled engines, such as PM-10 emissions standards and diesel fuel specifications. As a result of these 
measures, the projected outdoor ambient air concentration in California of PM-10 due to particulate 
matter emissions from diesel-fueled engines is expected to decrease 43 percent by 2010 (California Air 
Resources Board, 1998c). 

Both U.S. EPA and CARB have proposed new rules to reduce cancer risk from diesel exhaust 
particulates. The proposed federal regulations, published in the Federal Register in June 2000, would 
substantially reduce - by 97 percent - the amount of sulfur in diesel fuel, allowing for the use of catalytic 
filters (similar to the catalytic converters that have been required on passenger cars for many years) that 
can reduce emissions from diesel trucks. Along with the new fuel rules, U.S. EPA has proposed tighter 
emissions standards that would take effect beginning in 2007. The new rules are proposed to become 
final by late 2000. 

Separately, CARB in July 2000 published a draft plan that identifies a comprehensive program to further 
reduce emissions and resultant health risks associated with emissions of particulate matter from diesel 
engine exhaust (California Air Resources Board, 2000a). If approved by CARB, ARB staff will develop 
a series of new regulations covering both on-road and off-road (both mobile and stationary) diesel 
engines. This draft diesel risk reduction plan is an outgrowth of CARB's decision, which became 
effective in August 1999, to designate diesel exhaust particulates as a toxic air contaminant. CARB 
estimates that the future regulation, when fully implemented, could reduce the statewide cancer risk from 
diesel by 75 percent by 2010 and by 85 percent by 2020 (compared to an estimated 20 percent decrease 
in risk due to cleaner engines that would come about without the new rules). These future regulations 
would rely on retrofitting of existing engines, cleaner new engines (based on the U.S. EPA proposal), and 
low-sulfur diesel fuel, among other things. CARB is also examining alternatives to diesel fuel for 
powering heavy-duty engines, including trucks. The CARB board approved the draft diesel risk 



An exception exists for fugitive dust generated by truck movement operating within an industrial parcel. BAAQMD 
typically does include (and regulate) such emissions through the permit process for the facility. 



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reduction plan on September 28, 2000, and CARB staff will begin development of the regulatory 
program identified in the plan. 

To be conservative, the analyses in this report do not assume implementation of any of the above 
proposed rules or regulations. 

Stationary Emissions Sources 

To reduce public exposure to toxic air contaminants from stationary sources in the Bay Area, BAAQMD 
administers the Bay Area's Toxic Air Contaminant Control Program, which involves reviewing new 
stationary sources to ensure compliance with required emission controls and limits, maintaining an 
inventory of existing stationary sources of toxic air contaminants, and developing new rules and 
regulations to reduce toxic air contaminant emissions. Under the BAAQMD' s adopted Risk 
Management Policy, BAAQMD typically denies permits to new or modified stationary emissions 
sources where the emissions of toxic air contaminants from such sources, after installation of BACT for 
toxics (i.e., TBACT), would cause the probability of contracting cancer for the MEI to exceed 10 in a 
million. 

Odorous Emissions 

Regulations concerning odorous emissions apply to stationary emissions sources rather than mobile 
sources. BAAQMD Rules and Regulations (specifically. Regulation 7) place general limitations on 
odorous substances and specific emission limitations on certain odorous compounds. BAAQMD 
Regulation 7 applies when and if the BAAQMD receives validated odor complaints regarding a specific 
facility from 10 or more complainants in a 90-day period. The regulation restricts emissions of odorous 
substances that cause the ambient air at or beyond the property line to remain odorous after dilution with 
four parts of odor-free air. BAAQMD also regulates odorous emissions through enforcement of the 
public nuisance provisions in BAAQMD Regulation 1. 

REGIONAL AND SAN FRANCISCO AIR QUALITY CONDITIONS 
Criteria Air Pollutants 

BAAQMD operates a regional air quality monitoring network that provides information on ambient 
concentrations of criteria air pollutants, including ozone, carbon monoxide, and PM-10, which are the 
three pollutants of most concern. 

Monitored ambient air pollutant concentrations reflect the number and strength of emissions sources and 
the influence of topographical and meteorological factors. Table 8 is a summary of monitoring data 
collected at the BAAQMD' s Arkansas Street monitoring station (located at 16th and Arkansas Streets, 
about 1.5 miles northwest of Islais Creek) over the past five years for those pollutants for which the Bay 
Area is, or has been, designated "nonattainment." 



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As shown in Table 8, no exceedances of ozone or carbon monoxide concentrations have been recorded at 
the San Francisco monitoring stations over the past five years, but exceedances of the state PM-10 
standard have occurred on occasion (approximately 4 percent of the time, which is equivalent to 
approximately 15 days per year). PM-2.5 monitoring at the Arkansas Street station began in early 1999, 
and only one year of data is available. The highest 24-hour-average PM-2.5 concentration measured in 
1999 at the Arkansas Street was 71 micrograms per cubic meter, which exceeds the national standard of 
65 micrograms per cubic meter. Table 8 also shows that carbon monoxide concentrations are generally 
higher at the Ellis Street monitoring station (which only monitors carbon monoxide), located in the 
Van Ness Avenue corridor, than at the Arkansas Street station, located in the Potrero Hill area. 

Table 9 presents composite data for the past five years for the BAAQMD's entire regional network of 
monitoring stations. As shown in Table 9, the regional monitoring network has recorded exceedances of 
the state ozone standard on an average of approximately 24 days per year over the past five years. 
Coastal monitoring stations, such as those in San Francisco, Oakland, and San Rafael, record the fewest 
exceedances, while inland valley stations, such as those in Livermore, Concord, and Gilroy, record the 
most violations. Exceedances of national one-hour and national eight-hour ozone standards occur less 
frequently: on approximately 6 and 1 1 days per year, respectively. Table 9 also shows that no 
exceedances of the carbon monoxide standard have been recorded over the past five years. With respect 
to PM- 10, the regional monitoring network records exceedances of the state 24-hour standard relatively 
frequently (approximately 5.4 percent of the time over the three most recent years for which data are 
available, which is equivalent to approximately 20 days per year). A monitoring network for PM-2.5 in 
the Bay Area has only recently been established. Based on one year of data, the highest PM-2.5 
concentrations were collected at the stations in Vallejo, San Jose and San Francisco, and exceedances of 
the federal standard were recorded. According to the California Air Resources Board, annual mean 
concentrations of PM-2.5 in California's urban areas range from 10 to 25 micrograms per cubic meter 
(mg/m^), compared to the federal annual PM-2.5 standard of 15 mg/m^. Observed 24-hour average 
peaks reach levels as high as 160 mg/m^, compared to the 24-hour federal PM-2.5 standard of 65 mg/m^. 
Annual concentrations have declined at most urban sites in California since monitoring began in 1989. 

Several years of PM-2.5 data will be collected in the Bay Area prior to the preparation of a State 
Implementation Plan for PM-2.5, which will probably be required by around 2006 (California Air 
Resources Board, 2000b). 



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TABLE 8 

SUMMARY OF LOCAL MONITORING DATA FOR THE 
ARKANSAS STREET AND ELLIS STREET STATIONS, 1995-1999 



State National 
Standard Standard Pollutant Concentration by Year" 



Jrollutant 






lyyo 


1QQ7 




1QQQ 


Ozone 














Highest 1-hour average, ppm ^ 


0.09 0.12 


0.09 


0.07 


0.07 


0.05 


0.08 


Days over State Standard 
















u 


Days over National Standard 



















l-IiorriAcf S_hr\iir c\\if^TCkOf> nxwn 
OlgilCoL O'llUUl aVCia^Cj 


NA 08 








OS 


06 


Days over National Standard 



















Carbon Monoxide (Arkansas Street) 














Highest 8-hour average, ppm 


9.0 9 


4.4 


3.9 


3.5 


4.0 


3.7 


Days over Standard 



















Carbon Monoxide ( Ellis Street) 














Highest 8-hour average, ppm 


9.0 9 


5.5 


5.6 


5.8 


3.7 


4.6 


Days over Standard 



















Respirable Particulate Matter (PM-10) 














Highest 24-hour average, |ig/m'^ ^ 


50 150 


50 


71 


81 


52 


78 


Number of samples 




61 


61 


61 


61 


61 


Days over State Standard 







2 


3 


1 


6 


Days over National Standard 



















Annual average, |ig/m 


30 50 


22 


21 


23 


20 


23 


NOTE: Bold values are in excess of applicable standard. NA = Not Applicable or Not Available. 









Data was collected at the Arkansas Street monitoring station unless otherwise noted. The Ellis Street station monitors 
for carbon monoxide only. 

b 3 

ppm = parts per million; |J.g/m = micrograms per cubic meter. 

PM-10 is not measured every day of the year. The term, "number of samples" refers to the number of 24-hour- 
average PM-10 samples collected in a given year at the Arkansas Street monitoring station. 

SOURCE: California Air Resources Board, Summary of Air Quality Data, Gaseous and Particulate Pollutants, 
1996, 1997, 1998; 1998 and 1999 data are from the CARB website at www.arb.ca.gov/adam. 



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TABLE 9 

SUMMARY OF REGIONAL MONITORING DATA FOR THE 
SAN FRANCISCO BAY AREA AIR BASIN, 1995-1999 



State 
Standard 



National 
Standard 



Pollutant Concentration by Year ' 



Pollutant 






1995 


1996 


1997 


1998 


1999 




















0.09 


0.12 


V» J. w 


n 14 


0.11 


0.15 


IK 


Dave cw/pr ^tc\tf* ^tanH^rfi 






28 


34 


g 


29 


20 


Days over National Standard 






11 


8 





8 


3 


Highest 8-hour average ooni 


NA 


0.08 


0.12 


0.11 


0.08 


Oil 




Days over National Standard 






18 


14 





16 


9 


Carbon Monoxide 
















Highest 8-hour average, ppm 


9.0 


9 


6.1 


7.1 


6.3 


6.3 


6.3 


Days over Standard 





















Respirable Particulate Matter (PM- 10) 
Highest 24-hour average, pg/m^ 
















50 


150 


74 


76 


95 


92 


114 


Number of sample-days 






89 


88 


81 


NA 


NA 


Days over State Standard 






7 


3 


4 


5 


NA 


Days over National Standard 





















3 

Highest annual average, \ig/m 


30 


50 


26 


22 


24 


23 


25 



NOTE: Bold values are in excess of applicable standard. NA = Not Applicable or Not Available. 

^ This table summarizes the data from all of the monitoring stations within the Bay Area. 

ppm = parts per million; ilg/rr? = micrograms per cubic meter. 
^ PM-10 is not measured every day of the year. "Number of sample-days" refers to the number of days in a given year 

during which PM-10 was measured at one or more monitoring stations in the Bay Area. 

SOURCE: California Air Resources Board, Summary of Air Quality Data, Gaseous and Particulate Pollutants, 
1996, 1997, 1998; 1998 and 1999 data are from the CARB website at www.arb.ca.gov/adam. 



Toxic Air Contaminants 

BAAQMD also operates a regional monitoring network that collects ambient concentration data on some 
of the more pervasive toxic air contaminants. Table 10 summarizes three years of available toxic air 
contaminant concentration data collected at the air quality monitoring station located on Arkansas Street 
in San Francisco and compares the data with the concentration data based on the entire regional network 
of toxic air contaminant monitoring stations in the Bay Area. Table 10 indicates that ambient toxic air 
contaminant concentrations at the Arkansas Street station are generally similar to, or less than, the 



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TABLE 10 

SAN FRANCISCO, ARKANSAS STREET STATION, 
TOXIC AIR CONTAMINANT CONCENTRATIONS, 1994, 1996, 1998 

San Francisco Station ^ As Percent of Bay Area 

Mean Concentration (ppb) ^ '^ Mean Concentration ^ 

Toxic Air Contaminant 1994 1996 1998 1994 1996 1998 



Methylene Chloride 


0.69 


0.50 


0.43 


99% 


71% 


96% 


Chloroform 


0.01 


0.01 


0.02 


100% 


50% 


200% 


Methyl Chloroform 


0.41 


0.24 


0.09 


64% 


77% 


75% 


Carbon Tetrachloride 


0.11 


0.10 


0.10 


100% 


91% 


100% 


Trichloroethylene 


<0.08 


<0.08 


0.04 


100% 


100% 


80% 


Benzene 


1.16 


0.55 


0.66 


89% 


100% 


106% 


Perchloroethylene 


0.17 


0.09 


0.15 


68% 


45% 


100% 


Toluene 


3.69 


1.72 


1.96 


137% 


83% 


119% 


1,3-Butadiene 


<0.45 


0.18 


0.33 


100% 


86% 


94% 



^ Data for San Francisco are from the air quality monitoring station on Arkansas Street in San Francisco, which is located 

approximately 1 .5 miles northwest of Islais Creek, 
b ppb = parts per billion. 

c "Mean Concentration" is the arithmetic average of the air samples collected in each of the given years at the 15 monitoring 
stations in the Bay Area. In calculating the mean, samples with concentrations less than the "level of detection" (LOD) were 
assumed to be equal to one-half the LOD concentration. 

^ These percentages compare San Francisco measured concentrations to the average for the entire Bay Area. For example, 
100% indicates that San Francisco's mean concentration is the same as the mean concentration calculated based on the data 
from all of the monitoring stations in the Bay Area; 50% indicates that San Francisco's mean concentration is one-half that of 
the mean concentrations for the entire Bay Area. 

SOURCES: Bay Area Air Quality Management District, Toxic Air Contaminant Control Program, Annual Report, 1994, August 
1995; Bay Area Air Quality Management District, Toxic Air Contaminant Program, Annual Report, 1996, 
December 1997; Bay Area Air Quality Management District, Toxic Air Contaminant Program, Annual Report, 
1998, December 1999. 



average concentrations of those pollutants measured at other stations in the Bay Area. The data in 
Table 10 show that ambient benzene levels declined substantially in 1996 with the advent of Phase 2 
reformulated gasoline. Due largely to the observed reductions in ambient benzene and 1,3-butadiene 
levels, the average cancer risk in the Bay Area from ambient levels of toxic air contaminants has 
declined though the 1990s. Based on region-wide monitoring data for year 1998, the incremental cancer 
risk from exposure to ambient levels of toxic air contaminants - excluding diesel particulate matter - has 
been estimated to be 199 in a million, which is over 40 percent less than had been estimated for year 
1993 (Bay Area Air Quality Management District, 1999b). 

Diesel particulate matter consists of more than one compound, making monitoring more difficult than for 
the single TACs listed in Table 10. However, based on a limited amount of data, CARB has estimated 



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the Statewide, ambient, "population-weighted," cancer risk due to essentially all toxic air contaminants, 
based on year 2000 emissions, at 758 in 1 million, of which 540 in 1 million, or about 70 percent, is 
estimated to be due to diesel particulate (California Air Resources Board, 2000a). That is, the average 
individual in the State of California has a 0.8 in 1,000 chance - beyond the risk from other sources, 
including hereditary factors and exposure to other substances - of developing cancer due to toxic air 
contaminants in the ambient air. The average risk in the Bay Area is less than the statewide "population- 
weighted" average since the latter is influenced heavily by the large numbers of people living in the Los 
Angeles metropolitan area. The average risk from ambient toxic air contaminants is approximately 
30 percent less in the Bay Area than in the South Coast Air Basin (i.e., the Los Angeles metropolitan 
area) and approximately 17 percent less in the Bay Area than that calculated for the statewide 
"population-weighted" average (California Air Resources Board, 1998b). 

EXISTING EMISSIONS WITHIN PROJECT VICINITY 

Existing emissions sources within the project vicinity include large stationary sources, such as the 
Potrero and Hunters Point power plants, and other stationary sources, as well a mobile sources. The 
smaller stationary sources in the area, such as paint shops and small boilers, emit quantities of emissions 
that are substantially less than the mobile sources and the power plants. Mobile sources include autos 
and trucks traveling on Interstate 280, located approximately one mile west of the project site, and auto 
and trucks traveling on nearby Third Street and other local streets. 



SENSITIVE RECEPTORS 

Some land uses are considered more sensitive than others to air pollution. The reasons for greater than 
average sensitivity include pre-existing health problems, proximity to emissions source, or duration of 
exposure to air pollutants. Schools, hospitals and convalescent homes are considered to be relatively 
sensitive to poor air quality because children, elderly people and the infirm are more susceptible to 
respiratory infections and other air quality-related health problems than the general public. Residential 
areas are also sensitive to poor air quahty because people usually stay home for extended periods of time. 

The project area contains primarily cargo shipping, ship repair yard, industrial, and service, storage, and 
light industrial uses; open space at Warm Water Cove, along the north and south banks of Islais Creek, 
and at Pier 98, Heron's Head Park; and vacant land. No residential uses are located within the project 
area; the nearest residential areas are those in the Bay view-Hunters Point neighborhood (about one-half 
mile or more south of the project area), atop Potrero Hill (about one-third of a mile or more west and 
northwest of the project area), along Third Street (about one-half mile or more southwest of the project 
area), and in the small community known as Dogpatch, a block west of Third Street near 22nd Street. In 
the vicinity of the proposed Illinois Street Intermodal Bridge, there are existing vacant lands and 
industrial/manufacturing uses. 

A 1997 hospitalization study conducted by physicians from the San Francisco Department of Public 
Health and the University of California at San Francisco (Aragon and Grumbach, 1997) indicated that 



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hospitalization rates for asthma, hypertension, diabetes, and congestive heart failure are higher in the 
Bay view/Hunters Point area than in other parts of San Francisco. The study also reported that the Bay 
Area has among the highest age-adjusted breast cancer rates in California and that, while white women in 
San Francisco had a higher rate of breast cancer, black women were more likely to die from breast 
cancer. In the predominantly African-American Bay view-Hunters Point neighborhood, the study 
reported an 87 percent higher age-adjusted death rate from breast cancer than for the City as a whole. 
The study also found that Bay view-Hunters Point rates for other cancers, including female cervical 
cancer and male prostate and lung cancer, were higher than in most San Francisco neighborhoods. 

The study did not evaluate the cause(s) of the observed higher rates of these ailments, and no inferences 
can be made regarding the relationships between industrial emissions, mobile emissions, other sources, 
and health problems in the area. A detailed study, considering health access issues such as availability of 
regular medical care, ability to pay, diet, and others, as well as environmental factors such as pollution, 
would be required to begin to address the causes of poor health outcomes in the Bay view-Hunters Point. 
Such a study is beyond the scope of this SEIR. However, because of the location and concentration of 
uses proposed by members of the Industry Group and the sensitivity of nearby populations, this SEIR 
goes well beyond the typical level of air quality analysis in EIRs to address potential health effects of 
localized air pollution (see p. 91). 



IMPACTS 



SIGNIFICANCE CRITERIA 

The City has not formally adopted CEQA significance criteria, but generally considers a project to have a 
significant effect on air quality if it would (1) conflict with or obstruct implementation of the applicable 
air quality plan; (2) violate any air quality standard or contribute substantially to an existing or projected 
air quality violation; (3) result in a cumulatively considerable net increase of any nonattainment 
pollutant; (4) expose sensitive receptors to substantial pollutant concentrations; or (5) create 
objectionable odors affecting a substantial number of people. 

BAAQMD has published a set of recommendations that provide specific guidance on evaluating projects 
under CEQA relative to the above general criteria (Bay Area Air Quality Management District, 1999a). 
For temporary construction-phase impacts, BAAQMD recommends a qualitative approach that focuses 
on the dust control measures that would be implemented. If appropriate mitigation measures are 
implemented to control PM-10 emissions, then the impact from construction would be less than 
significant. 

For evaluating long-term operational emissions increases on a regional basis, effects are assessed by 
evaluating the total amount of criteria pollutants that the project would emit throughout the Bay Area 
airshed. Based on BAAQMD guidance, this report uses a criterion of 80 pounds per day or 15 tons per 
year from indirect sources (such as autos, trucks, trains, and ships) to identify projects that generate 
significant increases in regional emissions of ROG, NO^^, or PM-10. BAAQMD recommends that 



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cumulative air quality effects be discussed with reference to the consistency of a project to the regional 
Clean Air Plan. The BAAQMD recommendations are used herein to identify significant regional air 
quality effects of the project and significant cumulative effects. 

The assessment of local impacts is conducted through dispersion modeling to evaluate the concentration 
of particular pollutants on nearby receptors. This approach is used for carbon monoxide, which unlike 
other criteria pollutants, does not disperse readily over wide areas and is therefore more appropriately 
examined nearer the source. For this report, carbon monoxide concentrations are modeled at selected 
intersections (where two separate roadway sources come together, resulting in the highest localized 
concentrations) and compared against the state standard for one-hour and eight-hour periods of 20 parts 
per million (ppm) and 9 ppm, respectively. 

This report also evaluates localized concentrations of respirable particulate matter (PM-10), using a 
threshold that is equivalent to the standards used by BAAQMD to identify significant air quality impacts 
under their New Source Review rule (BAAQMD Regulation 2-2-233). Specifically, this SEIR uses 
concentration thresholds of 5.0 micrograms per cubic meter, 24-hour-average, and 1.0 microgram per 
cubic meter, annual average, to identify "substantial" contributions to existing or projected PM-10 
exceedances, which would be considered a significant effect. 

As described in the setting section, the impact of toxic air contaminants is evaluated based on a potential 
to increase the occurrence of cancer and is typically reported as an additional number of cancer cases, 
compared to the risk that would exist without exposure to the pollutant in question. This risk is reported 
as n chance in 1 million (or n cases per 1 million persons), where n is the number of additional cases of 
cancer that could be expected due to the pollutant in question. This report uses an incremental risk of 
10 in 1 million (10 additional cancer cases per million persons over a lifetime (70- year) exposure, or a 
1 in 100,000 chance of a single individual developing cancer, beyond the pre-existing risk) as the 
significance threshold, based on the BAAQMD' s procedure for permitting of stationary sources, which 
typically uses 10 in 1 million as the standard below which individual projects may be permitted. 

IMPACT ASSESSMENT METHODOLOGY 

Construction-period impacts were evaluated qualitatively and with reference to the dust control measures 
that can be implemented to reduce the temporary air quality effects associated with construction. 
Operational impacts were evaluated quantitatively through estimates of pollutant emissions and 
concentrations. Operational impacts were examined for two years: 2003, when the Industry Group 
project components would be in operation, the Illinois Street intermodal bridge would be in place, and 
the Muni Third Street light rail line is anticipated to begin operations; and 2015, by which time the 



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Future Port Development described in the Project Description would occur.^'^ With implementation of 
the Industry Group components, there is anticipated to be a shift, over time, in the transport of aggregate 
raw materials used in the production of ready-mix concrete, from truck to ship. As described in 
Appendix A, approximately half of the aggregate would be brought to the project area by ship by 2003 
(and 2001), with this percentage increasing to 80 percent by 2015. These shifts in mode of transport are 
reflected in this analysis, as they are in the transportation analysis. 

Two separate operational analyses were conducted for both analysis years. One aspect of the analysis 
quantifies the net change in emissions due to project-related sources from a regional perspective 
(emissions occurring within the multi-county air basin), including emissions from stationary sources 
(e.g., industrial plants and the like) and from mobile sources (i.e., motor vehicles, ships, trains, etc.). The 
other aspect of the analysis identifies what portion of the regional emissions would be experienced 
locally. 

For the regional air quality analysis, mobile-source emissions are calculated regardless of where they 
occur within the Bay Area, to the extent that they result in new emissions, compared to existing 
conditions. This is the typical approach to air quality analysis, and takes into account emissions not only 
in the immediate project area, but also emissions from, for example, vehicle trips that begin outside the 
immediate area, or even outside San Francisco, and end within the project vicinity. This "emissions 
inventory" for the project does not count existing trips - for example, those being made to and from the 
existing ready-mix concrete plants in the Mission Bay area - because those trips would not represent a 
change from existing to future conditions, except to the extent that the distance traveled is anticipated to 
change. The resulting volumes of criteria air pollutants that are reported would affect the entire Bay 
Area air shed, and are not directly reflective of local conditions in the vicinity of the project components 
because only those emissions generated within the immediate vicinity would contribute meaningfully to 
the local concentrations of various pollutants; that is, for example, emissions from motor vehicles in the 
East Bay or from ships passing beneath the Golden Gate Bridge are dispersed and diluted such that they 
would have little air quality impact in Bayview-Hunters Point or Potrero Hill. 

To determine the local effects of increased emissions with the project, this EIR also quantifies local 
project emissions and effects, in particular, due to project-related stationary sources and related truck 
traffic, on the Bayview-Hunters Point neighborhood. These calculations are provided in recognition of 
the concentration of industrial uses proposed, and the anticipated corresponding concentration of truck 
traffic, and because a substantial volume of the Phase I vehicle trips related to the Industry Group project 
components are currently being made, under existing conditions, to and from other parts of 
San Francisco. For example, delivery of concrete is made from the existing Bode Gravel Company and 



Unlike the traffic analysis, no separate air quality analysis was conducted for 2001. This is because the trip generation from 
the Industry Group components would be the same in 2001 and 2003, but by 2003 there would be additional emissions from 
other sources in the project area, including cargo shipping at Piers 80 and 94-96, and assumed expansion of an existing 
recycling facility at Pier 96. Therefore, 2003 provides for a more conservative evaluation of short-term impacts. (The traffic 
analysis included 2001 to differentiate between "before" and "after" conditions vis-ii-vis the Third Street light rail line.) 



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C. AIR QUALITY - IMPACTS 



RMC Pacific Materials plants located on Third Street at 16th Street and at Mariposa Street, respectively. 
Existing delivery of asphalt concrete is made to locations in San Francisco from plants in Berkeley and 
in Brisbane. Therefore, the change in location of, for example, the Bode and RMC concrete plants, 
would result in very little change in emissions viewed from a regional perspective, although there would 
be the potential for a proportionately larger increase in the concentrations of certain key emissions in the 
immediate vicinity of the new plants (with a corresponding decrease in emissions concentrations at the 
existing locations). These localized calculations report results for carbon monoxide concentrations at 
local intersections, as well as concentrations of respirable particulate matter (PM-10) and diesel 
particulate matter. 

Like the regional emissions calculations, these local calculations include emissions from on-site 
stationary sources and emissions from vehicle trips, train trips and ships. However, in this instance, the 
relocated stationary sources (ready-mix plants and proposed asphalt plant) would result in increased 
emissions within the immediate area, even if their effect on regional emissions would be negligible. 
With regard to vehicle trips, only trips within the project vicinity are counted in this local emissions 
calculation. For the Industry Group components, a maximum trip length of three miles to or from Third 
Street at Islais Creek - the approximate center point of the Industry Group sites - was used. For this 
local calculation, trucks traveling in excess of three miles (to the north) were not assumed to generate 
emissions that would directly affect the neighborhood. Therefore, with regard to existing trips - for 
example, those being made to and from the existing ready-mix concrete plants in the Mission Bay area - 
this local inventory only includes the emissions generated by that portion of the trips that occur between 
the existing concrete plants and Islais Creek, which is the change from existing to future conditions. In 
addition, project-related emissions from trucks currently traveling to and from the south were not added 
to this local inventory, because these truck emissions were considered to be already present in the 
immediate neighborhood. 

Both sets of emissions estimates (regional and local) include stationary and mobile sources associated 
with the various project components. For stationary-source emissions, the calculations were based on 
information contained in BAAQMD permit applications for those projects for which draft applications 
have been prepared; information was extrapolated to the analysis of other similar uses. For mobile- 
sources, emissions were calculated based on published emission factors for specific vehicle types and on 
vehicle-miles-traveled figures generated by the traffic analysis. The net change in emissions due to the 
project from the regional perspective was then compared with the applicable emissions-based 
significance thresholds. The net change in emissions from a project-area perspective were then used as 
input to air quality modeling for carbon monoxide, PM-10, and diesel particulate. 

With respect to concentrations, carbon monoxide concentrations were evaluated using carbon monoxide 
protocols developed at U.C. Davis for transportation projects (Institute of Transportation Studies, 1997). 
The screening-level protocol was used to identify intersections where more detailed analysis should be 
conducted, and the more detailed protocol was then applied to those identified intersections using 
Caltrans' line-dispersion model, CALINE4. PM-10 concentrations levels due to project sources were 



Case No. 1999.377E 



81 

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III. ENVIRONMENTAL SETTING AND IMPACTS 

C. AIR QUALITY - IMPACTS 

calculated using the Industrial Source Complex (ISC) dispersion model. The estimated carbon monoxide 
concentrations based on the protocols and CALINE4 were then added to estimated background 
concentrations and the totals were compared against the applicable ambient carbon monoxide standards. 

Project-related PM-10 concentration estimates were made for approximately 16 receptor locations in the 
nearby residential area. A component of PM-10 derives from combustion of diesel fuel, and the ISC 
modeling results were tabulated such that the diesel PM-10 concentrations could be extracted from the 
results for total PM-10 concentrations to provide the basis for calculating the incremental cancer risk 
from diesel PM emissions from project-related sources. 

CONSTRUCTION-PERIOD IMPACTS 

Grading and other ground-disturbing construction activities would temporarily affect local air quality 
intermittently during construction activities for each project component, causing a temporary increase in 
particulate dust and other pollutants. Heavy equipment would generate fugitive dust and would emit 
combustion products, including ozone precursors (ROG and NOx), carbon monoxide, sulfur dioxide, and 
PM-10, but the most significant emissions would be fugitive dust. 

Fugitive dust emission during demolition and excavation would increase particulate concentrations 
within the project area. Dustfall can be expected at times on surfaces within 200 to 800 feet. Under 
winds exceeding 12 miles per hour, localized effects including human discomfort might occur downwind 
from blowing dust. Construction dust is composed primarily of particularly large particles that settle out 
of the atmosphere more rapidly with increasing distance from the source and are easily filtered by human 
breathing passages. In general, construction dust would result in more of a nuisance than a health hazard 
in the vicinity of construction activities. About one-third of the dust generated by construction activities 
consists of smaller size particles in the range that can be inhaled by humans (i.e., PM-10), although those 
particles are generally inert. Persons with respiratory diseases immediately downwind of the site could 
be sensitive to this dust. 

The Illinois Street bridge would require minimal grading. Some earthmoving and grading would be 
required as part of the improvements to connecting rail beds and roads, but this would be no more 
extensive than typical urban street repaving operations. In general, with the exception of the Mission 
Valley Rock / Bode Gravel Company sites at Pier 92, most of the Industry Group project components 
would be located on land that is currently paved, and ground disturbance for grading and earthmoving 
would be limited. Buildings and other structures to be constructed would be relatively small and/or 
temporary structures, without a requirement for massive foundations, and existing buildings would be 
used as part of many of the project components. 

Much of the potential future development on Port lands assumed in this analysis would occur on unpaved 
lands. Because the terrain is flat, however, grading would not be expected to be extensive, unless 
subsurface parking or other excavation were required. Up to about 100 acres could be developed, about 
three-fourths of which is currently unpaved. Development would occur in stages, over the next 15 years. 



Case No. 1999.377E 



82 

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ni. ENVIRONMENTAL SETTING AND IMPACTS 



C. AIR QUALITY - IMPACTS 



with the volume of PM-10 emitted from any given project dependent on the area of earth being graded or 
otherwise disturbed. Uncontrolled PM-10 emissions can total about 51 pounds per day per acre 
(BAAQMD, 1999a, p. 28). 

BAAQMD has identified a set of feasible PM-10 control measures for construction activities, and 
mitigation was included in the Waterfront Plan EDR. to reduce construction-related air quality impacts to a 
less-than-significant level; a revised version of this mitigation measure is included in this SEIR as 
Mitigation Measure No. C-5 (see p. 148). With implementation of this measure, construction-related air 
quality effects would be reduced to a less-than-significant level. 



OPERATIONAL IMPACTS 



Regional Air Quality Analysis 

Regional emissions resulting from operations were calculated based on information supplied by the 
applicants and on emission factors released by U.S. EPA and CARB. The emissions of criteria pollutants 
were estimated for maximum daily and annual operations, and they include emissions from stationary 
sources (i.e., fixed equipment) on the project sites, from commuter trips, from haul truck trips, ships, and 
rail engines for those Industry Group project components that would handle construction materials, and 
from buses at the Coach USA site. Assumptions used to quantify project emissions are described in 
Appendix D, Air Quality. Additional background for the air quality assumptions can be found in 
Appendix A, Assumptions for Production of Construction Aggregates, and Appendix C, Transportation. 

The regional project emissions inventory is summarized in Table 11, where the results are compared with 
B AAQMD-recortmiended significance thresholds, for both daily and annual emissions. Tables 12 
through 15 provide a component-by-component breakdown of the emissions estimates that provided the 
basis for summaries shown in Table 11. Table 1 1 shows that the maximum daily emissions of reactive 
organic gases (ROG), nitrogen dioxide (NO^), and respirable particulates (PM-10) from all project 
components combined would exceed the significance threshold of 80 pounds per day in both 2003 and 
2015. The significance threshold for annual emissions of 15 tons per year would also be exceeded for 
ROG and NOx in each year. Therefore, the project would result in a significant effect with regard to 
emissions of criteria pollutants. This significant impact would occur regionally within the multi-county 
air basin and are not directly reflective of local conditions (see "Local Air Quality Analysis," p. 89, for a 
discussion of project effects on localized emissions concentrations). This impact cannot be reduced to a 
less-than-significant level because of the magnitude of the project. 

As seen in Table 1 1, the source of the greatest amount of emissions would be ship and rail traffic, 
particularly on days when ships call at the Port's terminals. (The daily emissions data presented in 
Table 1 1 and Tables 12 and 14 are indicative of days when ships call.) As indicated in Table 12, roughly 
60 percent of the NO^ would be generated, on a daily basis, by the Industry Group components and the 
remainder by non-Industry Group shipping. On an annual basis, however, the split would be reversed. 



Case No. 1999.377E 83 Southern Waterfront SEIR 

ESA 990267 



III. ENVIRONMENTAL SETTING AND IMPACTS 
C. AIR QUALITY - IMPACTS 



TABLE 11 
ESTIMATED NET CHANGE IN 
REGIONAL POLLUTANT EMISSIONS, 2003 AND 2015^ 



ANALYSIS YEAR 2003 Maximum Daily Emissions (lbs./day) Significance 

Stationary Motor Ship and Pet. of Bay Criteria 

Pollutant Sources^ Vehicle Truck Rail Total Area ^ (Ibsiday) 



Reactive Organic Gases (ROG) 


98 


17 


-18 


221 


318 


0.04 


80 


Nitrogen Oxides (NOx) 


58 


4 


-125 


2,038 


1,975 


0.22 


80 


Particulate Matter (PM-10) 


15 


1 


-13 


79 


82 


0.02 


80 






Annual Emissions (tons/year) 




Significance 






Stationary 


Motor 




Ship and 


Total 


Criteria 




Pollutant 


Sources ^ 


Vehicle 


Truck 


Rail 


Emissions 


(tons/year) 




Reactive Organic Gases (ROG) 


10.2 


2.5 


-1.8 


7.7 


18.6 


15 




Nitrogen Oxides (NOx) 


6.0 


0.6 


-12.4 


74.5 


68.7 


15 





Particulate Matter (PM-10) 1.5 0.1 -1.4 2.8 3.0 15 

ANALYSIS YEAR 2015 Maximum Daily Emissions (lbs./day) Significance 

Stationary Motor Ship and Pet. of Bay Criteria 

Pollutant Sources'' Vehicle Truck Rail Total Area'* (Ibsiday) 



Reactive Organic Gases (ROG) 


135 


6 


3 


185 


329 


0.05 


80 


Nitrogen Oxides (NOx) 


79 


2 


18 


1,938 


2,037 


0.28 


80 


Particulate Matter (PM-10) 


30 


1 


1 


67 


98 


0.03 


80 






Annual Emissions (tons/year) 




Significance 






Stationary 


Motor 




Ship and 


Total 


Criteria 




Pollutant 


Sources'' 


Vehicle 


Truck 


Rail 


Emissions 


(tons/year) 




Reactive Organic Gases (ROG) 


14.1 


0.9 


0.8 


17.9 


33.7 


15 




Nitrogen Oxides (NOx) 


8.3 


0.3 


5.1 


170.3 


183.9 


15 




Particulate Matter (PM-10) 


2.5 


0.1 


0.3 


5.8 


8.7 


15 





^ This table provides estimates of the net change in regional emissions under the project case in 2003 and 2015 
relative to existing conditions. Total project emissions would be disbursed throughout the Bay Area, and would 
not be experienced locally except as described in the following sections (see "Local Air Quality Analysis"). 
See Tables 12-15 for emissions estimates of individual project components, and Appendix D for more detail. 

^ Based on BAAQMD permit applications. 

Includes non-truck vehicle emissions (i.e., employee and visitor vehicle trips). 

^ Percentage of total daily Bay Area emissions in 2003 and 2015 based on CARB emissions inventories. 

SOURCE: Environmental Science Associates. 



Case No. 1999.377E 



84 

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Southern Waterfront SEIR 



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m. ENVIRONMENTAL SETTING AND IMPACTS 



C. AIR QUALITY - IMPACTS 



with non-Industry Group shipping generating two-thirds of the NOx (see Table 13).^^ The approximately 
2,000 pounds per day of NOx that Phase I of the project as a whole would generate would be about 
0.2 percent of the total NOx generated throughout the Bay Area Air Basin in 2003. Ships, trains, and 
other off-road mobile sources are estimated to generate approximately 172,000 pounds per day of NOx 
throughout the region in 2003, and the project's ship and rail emissions would represent an increase over 
that projected amount of less than 1.2 percent. 

Emissions of all three pollutants generated by trucks from the Industry Group components in 2003 would 
decrease, compared to existing conditions, because of the shift in means of transport from trucks to ships 
and rail for much of the raw material used in the production of ready-mix concrete. Truck trips related to 
non-Industry Group Port activity would generate most of the rest of the NOx- By 2015 (see Table 1 1 and 
Tables 14 and 15), emissions would increase based on the increase in concrete and asphalt production 
and the corresponding increase in truck traffic, as well as the increase in cargo shipping at the Port. 
Some of the increase in vehicle emissions would be offset by improved emissions control technology 
that would be implemented over time under existing regulations. 

The impacts of the estimated increases in daily and annual region emissions would affect the entire Bay 
Area airshed. The emissions would be dispersed over a large area, as this regional analysis takes into 
account many activities that would occur over a broad expanse of the region (e.g., ships traveling from 
outside the Golden Gate and truck travel to and from various parts of the region). The local analysis that 
follows focuses on effects in the immediate vicinity of the Southern Waterfront. 

Local Air Quality Analysis 
Carbon Monoxide Concentrations 

In addition to the regional contribution to the total pollution burden, project-related traffic may result in 
localized "hot spots" or areas with high concentrations of carbon monoxide concentrations around 
stagnation points such as major intersections and heavily traveled and congested highways and 
roadways. Project-related traffic could add more cars and trucks, as well as cause existing non-project 
traffic to travel at slower, less pollution-efficient travel speeds. 

To evaluate "hot spot" potential, a microscale impact analysis was conducted adjacent to four 
representative intersections within the project area. It was assumed that if the relatively higher volumes 
of project-generated traffic at these intersections did not result in adverse impacts, impacts at other 
nearby intersections would experience similar or less substantial effects. For this analysis, local carbon 
monoxide concentrations were estimated using a protocol developed at U.C. Davis for analyzing project- 
level effects associated with transportation projects (Institute of Transportation Studies, 1997) and using 
the results of the traffic study prepared for this report. The estimates are shown in Table 16. 



The daily volumes do not directly translate to annual volumes by a common factor because, for purposes of a conservative 
analysis, daily volumes assume a minimum of one ship oall per day for those project components that would include 
shipping even when the annual total of ship calls averaged over the year is substantially less than one per day. 



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TABLE 16 

ESTIMATED CARBON MONOXIDE CONCENTRATIONS AT SELECTED 
INTERSECTIONS IN PROJECT VICINITY 

Concentrations (ppm)^ 



Averaging Existing + Existing + 2015 + 

Time Industry Phase I + Project 

Intersection (hours) Existing Group Bridge (Phase I & II) 



Third / Mariposa Streets 
AM Peak Hour 



10.9 
6.8 



11.7 
7.4 



11.7 
7.4 



4.6 
2.5 



Third / Cesar Chavez Streets 
AM Peak Hour 



6.4 
3.6 



6.2 
3.6 



5.9 
3.3 



5.2 
2.9 



Illinois / Cesar Chavez Streets 
AM Peak Hour 



5.6 
3.0 



5.6 
2.7 



10.8 
6.7 



8.7 
5.4 



Third Street / Evans Avenue 
AM Peak Hour 



9.7 
5.9 



8.5 
5.2 



7.8 
4.7 



9.0 
5.6 



^ Concentrations relate to a location 10 meters from the edge of the roadways that form the intersection. The carbon monoxide 
analysis focuses on the moming (a.m.) peak-hour because the project's effects on traffic congestion and related carbon 
monoxide concentrations are greater during that period than during the afternoon (p.m.) peak hour. The UC Davis 
Transportation Project-Level Carbon Monoxide Protocol (Revised December 1997) was used to develop these estimates 
based on a.m. peak-hour traffic volumes prepared for this report. Carbon monoxide estimates shown above include 
background concentrations of 4.5 ppm, one-hour average, and 2.3 ppm, eight-hour average for existing; 4.0 ppm, one-hour 
average and 2.0 ppm, eight-hour average for 2003; and 3.4 ppm, one-hour average and 1.7 ppm, eight-hour average for 2015. 

NOTE: The state one-hour average standard is 20 ppm; the state eight-hour average standard is 9 ppm. 

SOURCE: Environmental Science Associates. 



The U.C. Davis carbon monoxide protocol involves a screening-level analysis, which serves to identify 
which intersections under which scenarios require further, more refined, analysis. With respect to the 
four intersections evaluated for this analysis, the screening-level analysis was sufficient to demonstrate 
the no exceedances would occur in the vicinities of the intersections of Illinois Street / Cesar Chavez 
Street and Third Street / Evans Avenue. For the intersection at Third Street / Mariposa Street, the 
screening level analysis indicated the potential for an exceedance in 2015, but the more refined analysis 
indicated that no exceedance would occur. At Third Street / Cesar Chavez Street, the refined method 
was used for both 2003 and 2015 to show that no exceedances would occur. In general, the increase in 
carbon monoxide concentrations that would normally be associated with projected increases in traffic 
volumes and associated congestion would be offset by the continued turnover of motor vehicles with 
newer vehicles manufactured to meet increasingly stringent emissions standards set by federal and state 
agencies and the shift in transport of heavy freight from trucks to ships and rail. In summary, based on 
the modeled concentrations shown in Table 16, the project would not result in exceedances of carbon 



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monoxide standards, and therefore, the effect of the project on local carbon monoxide standards would 
be less than significant. 

Project Incremental PM-10 Concentrations 

To examine the potential health effects of localized emissions of particulate matter, including PM-IO and 
diesel particulate, dispersion modeling was conducted to determine whether the local concentration of 
such particulates would be markedly increased in the Bayview-Hunters Point neighborhood as a result of 
emissions due to the project. Particulates were selected for dispersion modeling because of their 
potential adverse effects on respiratory health. The sensitive receptors selected include several schools 
and parks nearest the project area, in Bayview/Hunters Point and on Potrero Hill. These sites were 
chosen because children tend to be more susceptible than healthy adults to certain effects of air pollution. 
Also, the school sites are representative of the exposure locations of the surrounding residential 
neighborhood. Figure 7 shows the receptor sites selected for analysis. 

Emissions that could affect PM-10 and diesel particulate were estimated for the project's stationary 
sources and for mobile sources serving the project's facilities up to 1.5 miles from the project site (see 
Appendix D for additional information). In estimating particulate emissions from stationary sources, the 
analysis took into account air pollution controls required by existing regulations. Each of the Industry 
Group project components, which would represent "stationary sources" of particulate emissions, is 
proposed to include "best available control technology" (BACT) to control emissions, consistent with 
current regulations. For aggregate-handling operations (Bode Gravel, Mission Valley Rock, RMC 
Pacific, British Pacific Aggregates), this includes maintaining a moisture content in the aggregate that is 
high enough to eliminate PM-10 "fugitive" emissions (wind-blown dust that could otherwise escape into 
the surrounding air). A water spray system would be installed at each aggregate-handling facility, 
including Bode Gravel, Mission Valley Rock, RMC Pacific, and British Pacific Aggregates. Fine 
aggregate material (sand) would be maintained with a moisture content of approximately 5 percent, 
because such material with a moisture content of 4.5 percent or more produces virtually no fugitive 
emissions. Coarse aggregate (gravel) would be kept damp on the surface, which would also virtually 
eliminate fugitive dust. Aggregate would be stored in bunkers at ready-mix and asphalt plants, rather 
than open piles, with water spray (including the use of surfactants, as necessary, to bind the water and 
dust to the aggregate) applied to maintain adequate moisture content to control emissions at both 
production and shipping/storage operations. ISG Resources, which would store fly ash - a finer, more 
powdery material than aggregate - in former grain silos, would install BACT dust collection equipment 
to accommodate truck and rail transport and would use pneumatic equipment for transfer of fly ash. 

The asphalt plant proposed by Mission Valley Rock (and potentially the British Pacific asphalt plant) 
would include controls on the drum mixer where the asphalt cement and aggregate are mixed. Drum 
mixer(s) would be fired with natural gas, consistent with BACT recommendations, and particulate 
emissions from the aggregate drying and mixing process would be controlled with a fabric filter, also 
consistent with BACT. Such filters can achieve control efficiency of greater than 99 percent. Emissions 



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SOURCE: Environmental Science Associates, Pittman & Hames Associates. 



» Figure 7 (Revised) 

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of toxic substances from the asphalt plant would include mostly benzene and formaldehyde which would 
volatilize when the asphalt cement is heated. Most of these emissions would occur at the drum 
mixer/dryer. Using emission factors recently reported by U.S. EPA for hot mix asphalt plants (U.S. 
Environmental Protection Agency, 2000) in the dispersion modeling analysis, the maximum 
carcinogenic risk at sensitive receptors was estimated to be 0.3 in a million. 

Table 17 provides the results of the PM-10 modeling for the years 2003 and 2015. The table shows that 
the maximum incremental contribution to 24-hour PM-10 concentrations for local stationary and mobile 
source emissions at any given receptor would be 1.2 micrograms per cubic meter in 2003 and 
1.6 micrograms per cubic meter in 2015. In both cases, these maximums would be well below the 
significance standard of 5.0 micrograms per cubic meter, and would be registered at Youngblood 
Coleman Playground, on Hudson Avenue at Mendell Street, which is the closest sensitive receptor 
downwind from the concentration of proposed Industry Group components along Islais Creek. This 
playground is located adjacent to the residential area on the hill overlooking Hunters Point shipyard. The 
PM-10 concentrations at all other receptors modeled (see Figure 7) would be lower than these values. 

Based on meteorological conditions (see Figure 6, p. 65), the maximum 24-hour concentration at 
Youngblood Coleman Playground would occur on fewer than 25 days per year, when winds are blowing 
from a north direction. Wind measurements in the area indicate that winds in the directions that would 
result in these conditions are infrequent, with winds from the north direction occurring about 7 percent of 
the time. Winds from the south/southeast occurring from 3 percent to 5 percent of the time, and would 
affect receptors to the northwest of the project area, but at lower maximum 24-hour concentrations than 
shown in Table 17. Winds in the project area are usually from the southwest through northwest, 
occurring about 65 percent of the time. For these westerly wind directions, pollutant emissions from the 
project would be transported out over the Bay. 

For the maximum annual average PM-10 concentrations. Table 17 shows that the maximum 
concentrations in 2003 would be 0.09 micrograms per cubic meter, while in 2015, the maximum 
concentration would be 0.12 micrograms per cubic meter. As with the 24-hour concentrations, these 
highest annual averages would be well below the significance standard of 1.0 microgram per cubic 
meter, and would be at Youngblood Coleman Playground. 

As stated in the discussion of significance criteria, the significance threshold used in this SEIR for 
PM-10 concentrations is 5.0 micrograms per cubic meter for a 24-hour average concentration, and 
1.0 microgram per cubic meter for an annual average concentration. These standards are based on 
BAAQMD's New Source Review procedures for new or modified stationary sources (BAAQMD 
Regulation 2-2-233). Because the maximum PM-10 concentration from local project-related stationary 
and mobile sources would be less than the significance criteria for both the 24-hour and annual averages, 
the project impact on local PM-10 concentrations would be less than significant. 



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TABLE 17 

MAXIMUM PM-10 CONCENTRATIONS AT SENSITIVE RECEPTORS 



24-hr. PM-10 

3 

Year concentration (/xg/m ) 



Significance threshold 




Annual PM-10 

3 

concentration (/xg/m ) 



Significance threshold 




2003 
2015 



1.2 
1.6 



5.0 
5.0 



0.09 
0.12 



1.0 
1.0 



SOURCE: Environmental Science Associates. 



Diesel Particulate Concentrations 

To calculate the incremental cancer risk from project-related diesel particulate emissions, diesel 
particulate concentrations were modeled separately. Table 18 summarizes the modeling results with 
regard to diesel emissions. The table shows that, in 2003, the maximum incremental risk of cancer from 
diesel particulate emissions resulting from the project is estimated to be 7.5 in 1 million (7.5 additional 
cancer cases per million persons, beyond the risk from other sources), based on 24-hours per day 
exposure over a period of 70 years. In 2015, the project's cancer risk from diesel particulate would be 
9.0 in 1 million. To put these values in perspective, as stated in the setting, the BAAQMD estimates that 
the incremental cancer risk from exposure to current ambient levels of toxic air contaminants - excluding 
diesel particulate matter - is 199 in a million, and the California Air Resources Board estimates the 
statewide cancer risk due to essentially all toxic air contaminants at 758 in 1 million, of which 540 in 
1 million, or about 70 percent, is estimated to be due to diesel particulate. 

As noted in the Setting, the analyses in this report do not assume implementation of any of the proposed 
rules or regulations regarding diesel emissions. Implementation of some or all of these proposals would 
reduce the cancer risk from diesel particulate to less than described here. 

As stated in the discussion of significance criteria, the significance threshold used in this SEIR for diesel 
particulate concentrations is 10 in 1 million (10 additional cancer cases per million persons, or a 1 in 
100,000 chance of a single individual developing cancer, beyond the pre-existing risk), based on the 
BAAQMD permitting procedure for stationary sources. Because the maximum cancer risk would be less 
than the significance criterion, the project impact relative to diesel particulate concentrations would be 
less than significant. 

Odorous Emissions 

The BAAQMD CEQA Guidelines provides buffer distances that can be used to identify areas where 
significant impacts from proposed odor sources, such as an asphalt batch plant, could occur. Generally, 
odor impacts at sensitive receptor locations beyond the identified buffer distances can be presumed to be 
less than significant without further analysis. For sensitive receptors located within the buffer distances. 



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TABLE 18 

MAXIMUM DIESEL PARTICULATE CONCENTRATIONS AND 
RISK AT SENSITIVE RECEPTORS 



Annual concentration 
3 

Year (|Jg/ni ) Incremental risk Significance Threshold 

2003 0.025 7.5 in a million 10 in a million 

2015 0.030 9.0 in a million 10 in a million 

SOURCE: Environmental Science Associates. 



a more detailed odor impact analysis is generally warranted. For an asphalt batch plant, the BAAQMD- 
recommended buffer distance is I mile. 

The asphalt plant that could be constructed and operated between the Port and Mission Valley Rock 
would be a potential source of odors and odor complaints. Emissions of volatile organic substances, 
including toxic and odorous substances, can occur from heated asphalt cement that is used in production 
of asphalt concrete. Such emissions usually emanate from the drum mixer, where the asphalt cement is 
mixed with aggregate to create asphalt concrete. Mission Valley Rock proposes to use a counter-flow 
type drum mixer, which prevents direct contact between the material being mixed and the hot exhaust 
gases in the dryer. Consequently, the temperature of the asphalt mix would be reduced, compared to 
other mixers, and vapor emissions, some of which are odorous, would be minimized. 

Residential areas are located within one mile of the potential asphalt plant site, generally to the south and to 
the northwest. The closest residences are located approximately one-half mile south of the potential asphalt 
plant site in the residential area that is south of Fairfax Avenue in the Bay view-Hunters Point neighborhood. 
Other, more distant, residences are located to the southwest and southeast. Odors may be perceived at these 
residences when the plant would be operating during periods when stagnant atmospheric conditions (i.e., 
little vertical air movement and low wind speeds) would coincide with winds blowing in their general 
direction. However, the confluence of these three factors (plant operation, stagnant atmosphere, and worst- 
case winds) would be rare since the plant would not normally operate during nighttime hours when stagnant 
conditions more frequently occur; high (near-ground-level) atmospheric stability rarely occurs during 
daytime hours when the plant would normally be in operation; and winds blowing in the direction of these 
residences occur only about 18 percent of the time , or approximately 65 days per year (based on the data 
shown in Figure 6). Thus, although the buffer distance between the proposed plant site and the nearest 
residential areas would not be ideal, the distance would be substantial, and operational and meteorological 
factors would tend to diminish the potential impact. 

The buffer between the proposed plant site and the nearest residential areas to the northwest would be 
about three-quarters of a mile. Winds in the direction of these residences occur about 9 percent of the 



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time (based on Figure 6 in the setting section). Thus, like the residences to the south, although the buffer 
distance between the proposed plant site and the nearest residential areas would not be ideal, operational 
and meteorological factors would tend to diminish the potential impact. 

In summary, the proposed asphalt plant could raise the potential for odor impacts and complaints, but the 
related impact would not be significant because the plant would be designed to minimize volatile 
emissions (including odorous emissions) and because favorable operational and meteorological factors 
would serve to diminish the possibility for annoying odors when most residents are home. In addition, as 
discussed in the setting section, the BAAQMD's Rules and Regulations provide a regulatory mechanism 
to remedy odor complaints in the unlikely event that they would become frequent. 

CUMULATIVE IMPACTS 

According to the BAAQMD CEQA Guidelines, because the project would exceed the regional 
significance criteria of 80 pounds per day and 15 tons per year for both ROG and NO^ (and for PM-10 on 
a daily basis), it would also result in a significant cumulative effect. It should be noted, however, that the 
project-specific significant and cumulative effects are largely a construct of the BAAQMD's analysis 
methodology, which are geared more to a single development project, rather than a series of project 
components analyzed together, as in this SEIR. This finding of significant effect with respect to air 
quality does not necessarily mean that emissions, when modeled at the local level, will exceed state or 
federal standards. 

For carbon monoxide, the dispersion modeling results presented in Table 16 characterize cumulative 
conditions because a background concentration is inherent in the analysis and because background traffic 
volumes were included in the transportation analysis on which the carbon monoxide analysis was based. 
Neither project-specific nor cumulative carbon monoxide concentrations experienced locally would be 
significant. 

For localized PM-10 and diesel particulate, it is more difficult to quantify a cumulative concentration 
from this project along with other past, present, and future sources because of the large number of 
potential sources and their different locations. Locally measured PM-10 concentrations (from the 
BAAQMD's Arkansas and Ellis Street stations) show exceedances of the state standard. Local diesel 
particulate emissions data are not available. PM-10 modeling for the project analyzed in this SEIR 
would not result in PM-10 concentrations exceeding the 5.0 milligrams per cubic meter daily standard or 
the 1.0 milligrams per cubic meter annual significance criteria, and modeling of cancer risk from project- 
generated diesel particulate would not exceed the standard of 10 in 1 million. Locally, emissions from 
project sources, including both stationary and mobile sources, would be combined with emissions from 
other sources, primarily including area traffic (local streets and freeways), as well as large stationary 
sources such as the Potrero and Hunters Point power plants. These cumulative concentrations cannot be 
easily quantified, given the array of sources in the existing environment, and are therefore considered 



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significant. Local concentrations of pollutants would continue to be affected by activity levels in the 
area, by climate conditions, and by improvements in technology and fuel formulae. 

A major cumulative project that may occur in the area is a proposal to expand the electrical power output 
of Southern Energy's Potrero power plant. A modeling analysis reported in the Application for 
Certification submitted to the California Energy Commission indicates that the maximum 24-hour 
average PM-10 increment would be about I.O microgram per cubic meter. This maximum increment, 
combined with the PM-10 increment from the project, would be below the significance threshold of 
5.0 micrograms per cubic meter. Furthermore, if the Potrero plant expansion is approved, it is expected 
that the existing Hunters Point power plant, on Evans Avenue at Hunters Point Expressway, would be 
closed, under an agreement between PG&E, the operator of the Hunters Point plant, and the City. 
Closure of the Hunters Point power plant would result in a decrease in emissions of both criteria 
pollutants and toxic air contaminants in the immediate vicinity of the residential area overlooking 
Hunters Point Shipyard. 

Cumulative air quality effects are typically discussed in terms of a project's consistency with the most 
recent Clean Air Plan (i.e., the '97 Clean Air Plan). Consistency with the plan is evaluated with 
reference to the population and employment assumptions used for the plan and with reference to 
Transportation Control Measures (TCMs). (The project would have essentially no growth-inducing 
effect, and thus, the project would be consistent with the population and employment assumptions in the 
plan.) The '97 Clean Air Plan identifies a list of Transportation Control Measures (TCMs) that are to be 
implemented by local governments. These TCMs include support for voluntary employer-based trip 
reduction programs; improvement of bicycle access and facilities; improvement of arterial traffic 
management; development of local clean air plans, policies, and programs; implementation of 
demonstration projects; and promotion of pedestrian travel and traffic calming measures (Bay Area Air 
Quality Management District, 1999a) The City and County of San Francisco administers programs that 
implement all of these TCMs, and, while Phase I of the project, by its nature, does not further any of the 
TCMs in particular, none of the project components would interfere with their implementation, and thus 
the project would not be inconsistent with the '97 Clean Air Plan. TCMs could be implemented as part 
of Phase II of the project, which would include development of more typical urban land uses. 

In summary, the project would result in a cumulative significant regional impact on air quality, in that 
daily volumes of the three criteria air pollutants of most concern - reactive organic gases (ROG), 
nitrogen dioxide (NO^), and respirable particulates (PM-10) - would exceed Bay Area Air Quality 
Management District (and SEIR) significance thresholds, and annual emissions of ROG and NO^ would 
also exceed annual thresholds. Cumulative concentrations of PM-10 and diesel particulate experienced 
locally, while unknown because of the wide array of sources in the existing environment, could exceed 
significance thresholds. Even though the project would not exceed new source criteria for PM-10 or the 
10 in 1 million risk level for particulates from diesel emissions, the project would add some increment to 
existing local PM-10 and diesel emissions. Monitoring date from the nearest monitoring stations 
indicates some exceedances of the state PM-10 standard. Therefore, to be conservative, these emissions 



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are deemed cumulatively significant, although the project itself would not have a significant effect with 
regard to local concentrations of PM-10 or diesel particulate. 



REFERENCES - Air Quality 

Aragon, Tomas, MD, MPH (San Francisco Department of Public Health), and Kevin Grumbach, MD 
(University of California at San Francisco), "Community Health Profile: Bayview-Hunters Point 
Health & Environmental Assessment Project. Summary of Preliminary Results from Community 
Health Profiles Research," Draft, July 19, 1997. 

Association of Bay Area Governments, Bay Area Air Quality Management District, Metropolitan 

Transportation Commission, Proposed Final San Francisco Bay Area Redesignation Request and 
Maintenance Plan for the National Ozone Standard, July 1994a. 

Association of Bay Area Governments, Bay Area Air Quality Management District, Metropolitan 

Transportation Conmiission, Proposed Final San Francisco Bay Area Redesignation Request and 
Maintenance Plan for the National Carbon Monoxide Standard, July 1994b. 

Association of Bay Area Governments, Bay Area Air Quality Management District, Metropolitan 
Transportation Commission, Ozone Attainment Plan for the 1 -Hour National Ozone Standard, 
1999. 

Bay Area Air Quality Management District, Bay Area '97 Clean Air Plan, December 1997. 

Bay Area Air Quality Management District, BAAQMD CEQA Guidelines, Assessing the Air Quality 
Impacts of Projects and Plans, revised December 1999a. 

Bay Area Air Quality Management District, Toxic Air Contaminant Control Program, Annual Report 
1998, December 1999b. 

California Air Resources Board, Proposed Amendments to Heavy-Duty Vehicle Regulations: 2004 
Emission Standards; Averaging, Banking and Trading; Optional Reduce Emission Standards; 
Certification Test Fuel; Labeling; Maintenance Requirements and Warranties, Staff Report: Initial 
Statement of Reasons, March 1998a. 

California Air Resources Board, Report to the Air Resources Board on the Proposed Identification of 
Diesel Exhaust as a Toxic Air Contaminant, Part A, Exposure Assessment, as approved by the 
Scientific Review Panel, April 22, 1998b. 

California Air Resources Board, The Toxic Air Contaminant Identification Process: Toxic Air 
Contaminant Emissions from Diesel-fueled Engines, Fact Sheet, October 1998c. 

California Air Resources Board, Proposed Amendment to the Area Designations for State Ambient Air 
Quality Standards and Proposed Maps of the Area Designations for the State and National 
Ambient Air Quality Standards, October 1999. 

California Air Resources Board, 2000 California Particulate Matter Monitoring Network Description, 
2000. 

California Air Resources Board, Proposed Risk Reduction Plan for Diesel-Fueled Engines and Vehicles, 
Public Draft, July 28, 2000a. 



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California Air Resources Board, Quarterly Report to the California Legislature on the Air Resources 
Board's Fine Particulate Matter Program, First Quarter 2000b. 

Environmental Science Associates, Pacific Gas & Electric Company's Application for Authorization to 
Sell Certain Generating Plants and Related Assets, Draft Environmental Impact Report, prepared 
for the California Public Utilities Commission, August 1998. 

Institute of Transportation Studies, University of California, Davis, Transportation Project-Level Carbon 
Monoxide Protocol, December 1997. 

U.S. Environmental Protection Agency, Emissions Standards for Locomotives and Locomotive Engines; 
Final Rule, Federal Register, April 16, 1998. 

U.S. Environmental Protection Agency, Control of Emissions of Air Pollution from New Marine 

Compression-Ignition Engines at or Above 37 kW; Final Rule, Federal Register, December 29, 
1999. 

U.S. Environmental Protection Agency, Hot Mix Asphalt Plants Emission Assessment Report, Draft 
Report, June 2000. 

D. HYDROLOGY AND WATER QUALITY 

SETTING 

WATER FEATURES AND DRAINAGE 

The project site is located along the shoreline directly adjacent to San Francisco Bay. Major water 
features include: Central Basin, an inlet to the Bay on the north side of the project area; Islais Creek 
Channel, which runs through the center of the project area; and India Basin, located on the south side of 
the project area. Average annual precipitation is about 21 inches. 

As stated in the Waterfront Plan FEIR, Islais Creek is a tidal inlet between Pier 80 and Pier 90. 
Historically, Islais Creek was the confluence of several small creeks (one of which is still extant in Glen 
Canyon) that carried runoff from the southeastern portion of San Francisco and entered the Bay just west 
of the western end of the existing tidal inlet. Urban development and alterations to the drainage system 
resulted in culverting of Islais Creek and channeling most of the stream flow from Islais Creek into the 
City's combined sewer and stormwater system. Currently, surface inflow to Islais Creek occurs during 
the rainy season through an outfall and two overflow points from the combined sewer and stormwater 
system along the creek channel as well as direct stormwater runoff from areas adjacent to the creek. The 
creek channel is approximately 4,800 feet long and varies in width from 325 feet at the western end to 
650 feet at the eastern end. The average depth is about 25 feet. 

Freshwater flow to the Bay from San Francisco has almost entirely been diverted to the City's combined 
sewer and stormwater system. Nearly all of the City drains to the combined sewer system, although 
some piers and adjacent areas along the waterfront drain directly to the Bay. These piers and waterfront 
sites drain either through isolated storm drain systems or by sheet flow to the Bay. Nearly all of the 



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Southern Waterfront project area drains directly to the Bay rather than to the combined sewer system, 
except for some sites along Illinois Street, such as the proposed Waste Resource Technologies site at Pier 
70, that drain to the combined sewer system. Currently, the portion of the Bay adjacent to the project 
area receives surface inflow from stormwater runoff from the piers and waterfront sites as well as from 
treated wastewater discharges and combined sewer overflows, as discussed below. 

WASTEWATER DISCHARGES AND OVERFLOWS 

The City is almost entirely served by a combined sewerage system, which collects and transports both 
sanitary sewage and stormwater runoff in the same set of pipes. Most natural drainage and stream flow 
in the City is also diverted to the combined sewer system. Flows to the combined sewer system along 
the east side of the City are transported to the Southeast Water Pollution Control Plant, on Phelps Street, 
about one-half mile southwest of Islais Creek, for treatment and then discharged to the Bay. During dry 
weather, all wastewater flows, consisting mainly of municipal and industrial wastewater, are treated to a 
secondary leveP^ at the Southeast Plant and discharged through the deep water Pier 80 Outfall, located in 
the Bay east of Pier 80 (east of the project area). During wet weather, the combined sewerage system 
collects large volumes of stormwater runoff in addition to municipal and industrial wastewater, and 
transports the combined flow to treatment facilities before eventual discharge to the Bay. Wet weather 
discharges occur through the Pier 80 Outfall or the Quint Street Outfall (in the project area on the south 
bank of Islais Creek one block west of the Third Street bridge). During periods of extreme wet weather, 
combined sewer overflows also occur at overflow control structures located along the waterfront. Two 
overflow points are located in the project area at the western head end of Islais Creek, where combined 
sewer overflows occur on average about ten times per year. For the discharges through the overflow 
structures, the combined sewage and runoff undergo primary treatment prior to discharge to the Bay; this 
consists of flow-through treatment to remove settleable solids and floatable materials. All discharges 
from the combined sewer system to the Bay, through either the outfalls or the overflow structures, are 
operated in compliance with permits from the California Regional Water Quality Control Board 
(California Regional Water Quality Control Board, 1994). 

The San Francisco Public Utilities Conmiission, which includes the Clean Water Program - the City's 
wastewater treatment agency - has undertaken an examination of cumulative effects of increased 
development on the City's east side relative to the potential to increase the volume of discharges to 
San Francisco Bay through the overflow structures. The PUC's 1998 "Bayside Study" evaluated several 
scenarios, beginning with a "base case" that included completion of Pacific Bell Park, then under 
construction, as well as the PUC's Sunnydale flood control project. Under the base case, which 
essentially represents existing conditions, the PUC estimated that a total of 31.1 billion gallons per year 
of stormwater and wastewater enter the Bayside portion of the city's combined sewer system - 
essentially the eastern 60 percent of the City. Of this amount, about 910 million gallons per year is 



Secondary Treatment involves from wastewater or sewage of organic matter using biological and chemical processes. This 
is a higher level of treatment than primary treatment, which is removal of floating and settleable solids using physical 
operations such as screening and sedimentation. 



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estimated to flow treated to the Bay in combined sewer overflows, representing about 2.9 percent of the 
total flow. 



BENEFICIAL USES 

The Water Quality Control Plan for the San Francisco Bay Basin (Basin Plan) identifies the following 
existing beneficial uses for the San Francisco Bay, Central and Lower portions: ocean, commercial and 
sport fishing; estuarine habitat; industrial service supply; fish migration; navigation; preservation of rare 
and endangered species; water contact recreation; non-contact water recreation; shellfish harvesting; and 
wildlife habitat. Central San Francisco Bay also is identified as having industrial process supply and fish 
spawning as existing beneficial uses. No "potential" beneficial uses are identified for these waters 
(California Regional Water Quality Control Board, 1995). 

Along the project area between Piers 70 and 96, the predominant water-dependent uses are cargo 
shipping, ship repair and maritime support. Between Piers 72 and 80, Warm Water Cove Park is a public 
open space used primarily for picnicking and viewing bay vistas. On infrequent occasions, sport fishing, 
water contact recreation and non-contact water recreation opportunities are also observed, but are 
dependent upon water quality conditions and tidal water levels. Islais Creek is used for small-vessel 
boating and other non-contact water recreation. At the mouth of Islais Creek on the south side, there is 
an existing wetland area where wildlife habitat is dependent upon water quality conditions. There are 
also wetlands (a tidal marsh) at Pier 98 (Heron's Head Park). 



WATER QUALITY CONDITIONS 

As described in the Waterfront Land Use Plan FEIR, water quality data for the Bay specific to the project 
area are sparse. Water quality conditions in the overall vicinity of the project area are best characterized 
by data collected for Central San Francisco Bay as part of the Regional Monitoring Program for the 
San Francisco Estuary by the San Francisco Estuary Institute (San Francisco Estuary Institute, 1997). 
Data from this on-going study, started in 1993, have indicated that in general, the Central Bay has the 
highest water quality in the estuary, probably due to the regular tidal flushing in this area. At the Verba 
Buena Island sampling station, the closest sampling station to the project area, the most recent 
monitoring data available for 1996 indicate that water quality conditions remain well within water 
quality objectives established by the Regional Water Quality Control Board for conventional water 
quality parameters and all trace elements. The 1996 data show lower levels for nearly all trace 
elements than the 1993 levels that were presented in the Waterfront Land Use Plan FEIR. 

In 1999, the Regional Water Quality Control Board listed the western portion of Islais Creek (west of 
Third Street) as a Toxic Hot Spot (California Regional Water Quality Control Board, 1999) because of 
sediment toxicity (sediments from Islais Creek were found in tests to cause mortality of sea urchin larvae 
and amphipods, a small crustacean); elevated concentrations of chemicals (including the pesticides 



Trace elements include silver, arsenic, cadmium, chromium, copper, mercury, nickel, lead, selenium, and zinc. 



Case No. 1999.377E 



101 

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III. ENVIRONMENTAL SETTING AND IMPACTS 



D. HYDROLOGY - SETTING 



chlordane and dieldrin, PCBs, polynuclear aromatic hydrocarbons, and metals including lead, mercury, 
and silver, among other constituents); and an impacted benthic community (low numbers of, and lack of 
diversity in, bottom-dwelling organisms). The City's Public Utilities Commission staff disagrees with 
the conclusions reached by the Regional Board and is currently engaged with the Board in further data 
collection and analysis activities related to sediment in Islais Creek (Lundgren, 2000). 

San Francisco Bay is also listed by the State Water Resources Control Board as an "impaired" water 
body, under Section 303(d) of the federal Clean Water Act, because of the presence of numerous 
pollutants, including high-priority substances such as copper, dioxin compounds, mercury, PCBs, Furan 
compounds, and nickel, as well as many other chemicals. Also listed as a high-priority "stressor" of the 
Bay's water quality are exotic species such as clams that have been introduced to the Bay in ship ballast 
water. 



REGULATORY FRAMEWORK 



Water Quality Regulation 

The federal Clean Water Act of 1972 and subsequent amendments, under the enforcement authority of 
the U.S. Environmental Protection Agency (U.S. EPA), established the National Pollutant Discharge 
Elimination System (NPDES) program to protect water quality of receiving waters. Under the Clean 
Water Act, discharge of pollutants to receiving waters is prohibited unless the discharge is in compliance 
with an NPDES permit. Discharge of municipal and industrial wastewater as well as stormwater runoff 
is regulated under NPDES permit requirements. The regulations initially focused on municipal and 
industrial wastewater discharges in 1972, followed by stormwater discharge regulations, which became 
effective in November 1990. The NPDES permit specifies discharge prohibitions, effluent limitations 
and other provisions (such as monitoring programs) deemed necessary to protect water quality. In 
California, the U.S. EPA has delegated the implementation and enforcement of the NPDES program to 
the State Water Resources Control Board and the Califomia Regional Water Quality Control Boards. 

The Porter-Cologne Water Quality Control Act (Division 7 of the Califomia Water Code) regulates 
water quality within Califomia and established the authority of the State Water Resources Control Board 
and the nine Regional Water Quality Control Boards. The San Francisco Bay waters are under the 
jurisdiction of the Regional Water Quality Control Board (RWQCB), San Francisco Bay Region. The 
RWQCB established regulatory standards and objectives for water quality in the Bay in the Water 
Quality Control Plan for the San Francisco Bay Basin, commonly referred to as the "Basin Plan" 
(Califomia Regional Water Quality Control Board, 1995). The Basin Plan identifies existing and 
potential beneficial uses (described above) and provides numerical and narrative water quality objectives 
designed to protect those uses. The RWQCB considers the beneficial uses of receiving water in 
establishing NPDES permit requirements in the San Francisco Bay region. 



Case No. 1999.377E 



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III. ENVIRONMENTAL SETTING AND IMPACTS 

D. HYDROLOGY - SETTING 

City NPDES Permits 

The City currently holds two NPDES permits from the RWQCB for discharges to the Bay in the project 
area. The first permit is for the Southeast Water Pollution Control Plant for discharges of treated 
wastewater through the Pier 80 and Quint Street outfalls. The second permit is for the Bayside wet 
weather facilities, which includes the discharges from the combined sewer overflow structures in Islais 
Creek. 

The City and County of San Francisco is currently exempt from the federal stormwater regulations under 
the NPDES program because it has a combined sewer system. Discharge of nearly all stormwater runoff 
from the City is covered under its existing NPDES permits, and the City is not required to have a 
separate municipal stormwater discharge permit. However, current federal proposals indicate that the 
City may be required to apply for a general stormwater permit that would require the City to develop and 
implement a stormwater control program in the areas that have separate storm sewers, such as those 
isolated areas along the waterfront in the project area. Application for such permits is anticipated for 
approximately August 2001 (Medbery, 1997). 

Industrial Stormwater NPDES Permit 

The federal Clean Water Act includes regulations requiring that stormwater associated with industrial 
activity that discharges either directly to surface waters or indirectly through municipal separate storm 
sewers must be regulated by an NPDES permit. This requirement would apply to project facilities 
located along the waterfront that drain through isolated storm drain systems directly to the Bay. Most 
industrial facilities, such as those proposed for the Southern Waterfront area, can comply with the 
NPDES industrial stormwater requirement through the Industrial Activities Stormwater General Permit 
adopted by the State Water Resources Control Board in 1997. Some industries may require an industry 
specific permit, and other may require an individual permit. The requirements for a General Permit are 
discussed below. 

In order to obtain coverage under the General Permit, facilities are required to file a Notice of Intent and 
to comply with General Permit conditions. Permit conditions include: discharge prohibitions for 
stormwater containing hazardous substances in excess of established quantities; pollutant controls using 
best available technology economically achievable, best conventional pollutant control technology, and 
best management practices; receiving water limitations; preparation and implementation of a Stormwater 
Pollution Prevention Plan (SWPPP); and preparation and implementation of a monitoring program. The 
SWPPP contains site-specific information to identify and evaluate sources of pollutants associated with 
industrial activities and to identify and implement site-specific best management practices to reduce or 
prevent pollutants associated with industrial activities in stormwater discharges. Best management 
practices may be non- structural (e.g., activity schedules, maintenance procedures, prohibitions of 
practices) or structural (e.g., treatment measures, runoff controls, overhead coverage) (State Water 
Resources Control Board, 1997). 



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III. ENVIRONMENTAL SETTDJG AND IMPACTS 



D. HYDROLOGY - SETTING 



Construction Stormwater NPDES Permit 

The federal Clean Water Act effectively prohibits discharges of stormwater from construction projects 
that encompass five or more acres of soil disturbance unless the discharge is in compliance with an 
NPDES permit. The State Water Resources Control Board has adopted a statewide General Permit for 
Stormwater Discharges Associated with Construction Activity; the current 1999 General Permit updates 
the previous 1992 General Permit. Although construction activities of less than five acres are not 
covered by this permit, those activities will be required to apply for a permit under Phase II regulations 
by August 2001 (State Water Resources Control Board, 1999). The construction stormwater regulations 
would apply to the various components of the proposed project, depending on the size of the construction 
site. 

The Construction Stormwater General Permit requires that where construction activity disturbs five acres 
or more, the land owner and/or contractor develop and implement a Stormwater Pollution Prevention 
Plan (SWPPP). This plan must specify best management practices that will prevent all construction 
pollutants from contacting stormwater, with the intent of keeping all products of erosion form moving 
off site into receiving waters. The permit also requires elimination or reduction of non-stormwater 
discharges to receiving waters and inspection of all best management practices. 

In order to obtain coverage under the Construction Stormwater General Permit, land owners are required 
to file a Notice of Intent prior to starting construction activities and to comply with General Permit 
conditions. These permit conditions include: discharge prohibitions for stormwater containing 
hazardous substances in excess of established quantities; pollutant controls using best available 
technology economically achievable, best conventional pollutant control technology, and best 
management practices; eliminating or reducing non-stormwater discharges; receiving water limitations 
that require immediate corrective action; preparation and implementation of a SWPPP; and preparation, 
implementation and retaining records of a monitoring program. The SWPPP contains site-specific 
information to identify and evaluate sources of sediment and other pollutants and to identify and 
implement site-specific best management practices to reduce or eliminate sediment and other pollutants 
in stormwater and non-stormwater discharges. The SWPPP must include measures for erosion and 
sediment controls, methods for construction waste handling and disposal, and post-construction erosion 
and sediment control requirements. Mitigation Measure D-1, p. 149, address the preparation of SWPPPs 
and would apply to the project area. 

IMPACTS 



SIGNIFICANCE CRITERIA 

The City has not formally adopted significance standards for hydrology and water quality impacts, but it 
generally considers that implementation of the Southern Waterfront projects would have a significant 
effect on hydrology and water quality if it were to: 



Case No. 1999.377E 104 Southern Waterfront SEIR 

ESA 990267 



ni. ENVIRONMENTAL SETTING AND IMPACTS 

D. HYDROLOGY- IMPACTS 

• substantially change absorption rates, drainage patterns, or the rate and amount of surface water 
runoff to the Bay; 

• substantially degrade water quality; 

• contaminate a public water supply; 

• substantially degrade or deplete groundwater resources or interfere with groundwater recharge; or 

• cause substantial flooding, erosion, or siltation. 

Criteria for evaluating surface and groundwater quality in the San Francisco Bay Area are based on 
beneficial uses and water quality objectives established by the Regional Water Quality Control Board, 
San Francisco Bay Region as authorized under the Porter-Cologne Water Quality Control Act and Clean 
Water Act. Both beneficial uses and water quality objectives are described within the Basin Plan. 

Given public concerns regarding combined sewer overflows, the change in the volume of discharge from 
the City's combined sewer system is assessed along with the potential for greater volumes and numbers 
of overflow events. 

Groundwater and flooding hazards are not discussed in this section because the Southern Waterfront 
project would have no impacts on either groundwater or flooding. In general, the project components 
would require minimal (shallow) excavation, and therefore, it is unlikely that groundwater would be 
encountered, and the project area is not within an area subject to flooding. The Illinois Street bridge 
would likely attain support from driven piles, which would penetrate groundwater. However, piles or 
piers typically would not cover a large area, and therefore groundwater recharge would not be adversely 
affected. Further, groundwater from this area is not used for a potable water supply. 

IMPACT ANALYSIS 

Changes in Stormwater Runoff and Wastewater Flows 

The proposed development in the Southern Waterfront area would result in changes in the volume of 
surface water runoff from stormwater due to changes in the extent of impervious surfaces and would 
change the volume of wastewater (sewage) and stormwater discharged to the Bay from the City's 
combined sewer system. In general, replacement of unpaved areas with structures, pavement or other 
impervious surfaces would reduce the infiltration of rainwater and would increase the volume of 
stormwater runoff flowing directly from the project site to the Bay. Development of commercial and 
industrial uses would also result in increased wastewater flows to the combined sewer system. Increases 
in volume of wastewater flows and any increase in the volume of stormwater runoff that is piped to the 
City's combined sewer system could in turn affect the volume of treated effluent and combined sewer 
overflows discharged to the Bay. Increases in direct discharge of stormwater runoff, treated effluent, and 
combined sewer overflows to the Bay could affect water quality (discussed below under Operational 
Effects on Water Quality). The changes in stormwater runoff are evaluated separately for the Industry 



Case No. 1999.377E 



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III. ENVIRONMENTAL SETTING AND IMPACTS 



D. HYDROLOGY- IMPACTS 



Group project components and for the future Port development that would occur by the analysis horizon 
year of 2015. 

This EIR assumes that for the Industry Group Projects neither the Port nor the tenants would construct 
on-site infrastructure related to stormwater collection, and there would be no new connections to the 
combined sewer system to capture stormwater runoff, because the Industry Group components would be 
considered interim uses (with leases limited in length such that major capital investment in storm 
drainage infrastructure would not be economically feasible). Therefore site conditions with respect to 
drainage infrastructure are anticipated to remain the same as existing conditions. Site locations currently 
draining to the Bay would continue to do so, and locations currently draining to the City's combined 
sewer system would continue as well. 

Under the Industry Group projects, the total site areas for all projects would be about 32 acres. Of this 
32 acres, about 25.5 acres is currently considered to be impervious surfaces, with pavement or structures 
built on it; the remaining 6.5 acres, consisting of most of the Mission Valley Rock-Bode Gravel site at 
Pier 92, is unpaved. Table 19 shows the estimated changes in impervious surfaces for each of the 
various project components. 

The Mission Valley-Bode site would be entirely paved with asphalt or concrete, in compliance with a site 
mitigation plan prepared for the Bode site (see discussion in Section III.F, Hazardous Materials, p. 130), 
resulting in the overall Industry Group projects being completely covered with impervious surfaces. 
This would increase runoff from the Industry Group sites by about 12 percent; the overall increase from 
all project component sites would be 3 percent. The increase in direct stormwater flow to the Bay would 
be approximately 1.4 million gallons per year. This can be compared to the approximately 47.8 million 
gallons per year currently discharged to the Bay as direct stormwater flow from the project area, and to 
the approximately 480 million gallons per year of treated combined sewer overflows currently 
discharged to Islais Creek (San Francisco Public Utilities Commission, 1998). (Runoff calculations are 
provided in Appendix E.) As discussed below under "Operational Impacts on Water Quality," any 
stormwater runoff from the proposed industrial uses would be required to comply with RWQCB 
regulations under the NPDES program and Mitigation Measure D.2, p. 149. For these reasons, the 
relatively minor increase in runoff associated with the Industry Group sites would be considered less 
than significant with mitigation. Resulting changes in water quality are discussed below. 

Future Port development would generate an estimated 300,000 gallons per day of wastewater, or dry 
weather flows. This would represent less than 0.4 percent of the current City wide total of 84 million 
gallons per day, and less than 0.5 percent of the 67 million gallons per day currently treated at the 
Southeast Water Pollution Control Plant. The Industry Group components would generate negligible 
wastewater flow, as on-site employment would be relatively small and neither stormwater nor process 
water would be directed to the City's combined sewer system in substantial volumes. The project impact 
on dry-weather flow and the incremental impact of wastewater flow on the volume of combined sewer 
overflows would be considered less than significant. 



Case No. 1999.377E 



106 

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Southern Waterfront SEIR 



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The approximately 100 acres where future Port development would occur is currently about one-fourth paved 
or otherwise covered with impervious surfaces. Table 19 shows the estimated changes in impervious 
surfaces associated with the future Port development. Under worst-case assumptions, the full build out of 
these projects would result in an increase of about 60 acres of impervious surfaces. This would represent an 
estimated 35 percent increase in surface water runoff from stormwater in the area occupied by the future Port 
development sites, based on rainfall, runoff and land use assumptions developed for the PUC's Bayside 
Cumulative Impact Analysis (San Francisco Public Utilities Commission, 1998). The estimated increase in 
runoff volumes would be about 12.5 million gallons per year, a 26-percent increase over existing runoff from 
the area occupied all project components combined. Together with Phase I components, the increase would 
be about 13.9 million gallons per year, or 29 percent more than existing runoff from all project component 
sites. (See Appendix E for runoff calculations.) 

The Waterfront Plan EIR assumed that storm drainage from up to 100 acres of Port land uses could be 
piped to the City's combined sewer system. This could result in a measurable increase in bayside flows, 
made up of treated effluent and combined sewer overflows. This runoff would contribute to a 
cumulative increase of approximately 44 million gallons per year in combined sewer overflows at Islais 
Creek. Even though this increase would be permitted, recent EIRs have conservatively found the 
cumulative increase in combined sewer overflows to be a significant impact.^^ Mitigation Measure D.3, 
p. 150, would reduce the project's contribution to a neghgible amount by directing stormwater flow to 
the Bay with appropriate treatment to meet regulatory requirements, instead of to the City's combined 
sewer system. 

As noted in the Setting, the San Francisco PUC's Bayside Study evaluated several scenarios for future 
development along the City's Bay shoreline. Table 20 presents modeling results from the PUC study for 
the "base case" (existing conditions) and for future cumulative conditions, including implementation of 
both phases of the proposed project analyzed in this SEIR, as well as buildout of the Mission Bay area 
and redevelopment of Hunters Point shipyard. Table 20 also presents an interim-year analysis for 
Phase I of the project (primarily implementation of the Industry Group components). 

Water Quality 

Operations associated with long-term implementation of the proposed Industry Group projects could 
result in detrimental effects on Bay water quality. These operations include water quality impacts 
associated with stormwater runoff from proposed developments and with maritime uses, such as shipping 
and boating activities, involving handling and storage of chemicals in proximity to the Bay. 



For further discussion of cumulative stormwater overflows, the reader is referred to Section 3.9, Water Resources Setting, 
and Section 4.9, Water Resources Impacts, in the Hunters Point Shipyard Reuse Final EIR, Case No. 1994.06 IE, Final EIR 
certified February 8, 2000; in particular, pp. 3-132 - 3-136, which describe the City's combined sewer system and existing 
conditions with regard to water quality in San Francisco Bay and the effects of combined sewer overflows, and pp. 4-78 - 
4-82, which describe impacts of the Hunters Point Shipyard Reuse Plan and cumulative effects on water quality related to 
combined sewer overflows. These pages are hereby incorporated by reference. The Hunters Point Shipyard Reuse Final 
EIR is available for review at the San Francisco Planning'Department, 1660 Mission Street, First Floor Planning Information 
Counter; and at the San Francisco Public Library, Main Library (Civic Center). 



Case No. 1999.377E 



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III. ENVIRONMENTAL SETTING AND IMPACTS 



D. HYDROLOGY- IMPACTS 



TABLE 20 

CHANGES IN STORMWATER FLOW AND COMBINED SEWER OVERFLOWS 



Bay side 





Base Case 








Cumulative including Project 




(Existing) 


Existing plus Industry Group 


(Phases I & 11)^ 






Volume 


Volume 


Change'' 


Pet. 


Volume 


Change'' 


Pet. 


Total Treated Effluent (mgy) 


30,203 


30,203 





N/A 


31,297 


1,094 


3.6% 


Total Bayside CSOs (mgy) 


910 


910 





N/A 


949 


39 


4.3% 


Islais Creek CSOs (mgy)<= 


481 


481 





N/A 


525 


44 


9.2% 


Total Bayside Flow (mgy) 


31,113 


31,113 





N/A 


32,246 


1,133 


3.6% 


% receiving Secondary Treatment 


87.3% 


87.3% 





N/A 


87.4% 


0.1% 




% receiving Primary Treatment 


9.7% 


9.7% 





N/A 


9.7% 


0.0% 




Stormwater Flow to Bay from 


47.8 


49.2 


1.4 


2.9% 


49.2 


1.4 


2.9% 


Project Area (mgy)<^ 
















Stormwater Flow to Bay from 


47.8 


49.2 


1.4 


2.9% 


61.7 


13.9 


29.1% 



Project Area - Mitigated (mgy)^ 



Notes: mgy - million gallons per year; CSOs - combined sewer system overflows. 

^ Assumes stormwater from future Port development (Phase II of the project analyzed in this SEIR) is directed to 
City's combined sewer system. Also assumes buildout of Mission Bay with separate stormwater system and 
"first flush"; redevelopment of Hunters Point Shipyard with separate stormwater system flowing to San Francisco 
Bay, and construction of new stadium and shopping mall at Candlestick Point (Scenario A2B2D2E2). With 
Mitigation Measure D.3, volume of combined sewer overflows would be less because all stormwater from the 
project analyzed in this SEIR would flow to the Bay following pre- treatment. 

^ Change from existing conditions. 

^ Islais Creek CSO volume included in Total Bayside CSO volume. 
Assumes all new runoff from SEER, project area (except Industry Group sites) would be piped to City's combined 
system. 

^ Assumes all new runoff would drain to bay (after pre-treatment; see Mitigation Measure D.3). 

Source: San Francisco Public Utilities Commission, 1998; Orion Environmental Associates; Environmental 
Science Associates. 



Stormwater runoff from urban areas is a known source of pollutants to receiving waters. Typical sources 
of pollutants could include fluid leaks from vehicles, brake pad wear, tire abrasion, pavement wear, 
sediments, pesticides from landscaped areas, and atmospheric deposition. Both oil and grease and 
sediments can act as a carrier for other pollutants as well as representing a type of pollutant. The types 
of pollutants may include metals, hydrocarbons, and organic pollutants as well as sediments. During 
rainstorms, these pollutants may be mobilized and transported in the stormwater runoff to receiving 
waters. Sometimes the first flush of each storm contains the highest concentration of pollutants, but 
release of pollutants to stormwater depends on rainfall patterns, intensity and site-specific conditions. 
These water quality effects could occur with stormwater runoff discharging directly to the Bay, unlike 
stormwater runoff discharging to the combined sewer system, which would undergo treatment at either 



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the Southeast Water Pollution Control Plant or the overflow control structures prior to discharge to the 
Bay. 

All industrial users that would discharge stormwater runoff either directly to the Bay by sheet flow or 
through isolated storm drain systems would be required to comply with NPDES permit regulations. 
These regulations, described above in the Setting, would likely be met through the Industrial Activities 
Stormwater General Permit adopted by the State Water Resources Control Board, but could alternatively 
be met through an industry specific permit or an individual permit. The construction aggregate-related 
Industry Group project components, for which sediment in stormwater runoff would be a primary water 
quality concern, would include facilities such as settling ponds and sediment basins to ensure that neither 
stormwater as sheet flow nor process water (for example, water used to wash out cement mixers) is 
transported directly to the Bay without removal of sediment and other solids. Much of the process water 
would be reused in Industry Group operations. 

Compliance with NPDES permit conditions, including preparation and implementation of a Stormwater 
Pollution Prevention Plan, would minimize potential water quality degradation associated with 
stormwater runoff. In addition, implementation of Mitigation Measure D.2 (implementation of source 
control Best Management Practices consistent with those identified in the Industrial / Commercial Storm 
Water Best Management Practices Handbook) and of measures identified in the Waterfront Land Use 
Plan EIR (and also presented in Section IV of this report) for tenants to participate in the Port's 
stormwater monitoring program would further reduce the potential for Bay water quality degradation. 
Therefore, long term water quality impacts associated with stormwater runoff from Industry Group 
project components would be considered less than significant with mitigation. 

The Port's planned location of an expanded dredge material handling facility at Pier 94 would result in 
runoff back to the Bay of decant water from dredge material placed at Pier 94. The Regional Water 
Quality Control Board (RWQCB) would require routine testing of the decant water to ensure that 
sediment levels are below accepted criteria, and that the water does not contain chemicals (e.g., heavy 
metals) or other constituents at levels in excess of regulatory requirements. If contaminant levels were 
in excess of applicable requirements, the RWQCB would require that the Port treat the decant water prior 
to discharging it to the Bay. Treatment could involve removal of settled solids, activated charcoal 
treatment, and other methods. Operation of the dredge material storage facility in compliance with the 
required discharge permit from the RWQCB would ensure that water quality effects on the Bay would be 
less than significant. 

Because the proposed Pier 94 dredge material storage site is a former landfill that is currently under 
regulatory oversight by the RWQCB, one of two approaches would be required prior to implementation 
of the dredge material expansion project:"^* either the landfill area could be capped with an impermeable 



Although the decant water would be Bay water being returned to the Bay after draining from the dredge material, federal and 
state regulations preclude discharge of such water if sediment or contaminant levels are excessively high. 
The former landfill at Pier 94 is discussed further on p. 123, in Section III.E, Hazardous Materials. 



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barrier to prevent decant water from draining out of dredged material and into and through the former 
landfill, or the RWQCB could determine, based on additional testing and sampling that would have to be 
performed by the Port, that infiltration of seawater through the former landfill would not adversely affect 
water quality in the Bay. Because implementation of the dredge material expansion project would have 
to occur in compliance with RWQCB regulations, effects of this project component on water quality 
would be less than significant. 

The future Port development that would occur by 2015 could have similar effects to those described for 
the Industry Group project components. Potential industrial and conmiercial activity on currently 
unprogrammed Port lands at Pier 70 and at the 90-94 backlands would likely entail placement of large 
areas of impervious surfaces (buildings and pavement), which during dry weather accumulate pollutants 
associated primarily with industrial or urban use. The stormwater runoff associated with the increased 
area of impervious surface, if collected in the City's combined sewer system, would increase demand on 
the Southeast Water Pollution Control Plant. A more detailed determination of potential impacts on wet 
weather combined sewer overflows would require review of detailed development plans, which are not 
known for any of the potential future development on Port lands. Any such future development 
proposals, which would be defined through a community planning process, would include this project- 
specific information, which would then be reviewed by the Port and other City agencies such as the 
Public Utilities Commission, for potential infrastructure improvements, and would be subject to further 
environmental review. 

Under the potential future Port development projects, about 200,000 square feet of maritime industry 
uses are proposed for the Pier 70 Maritime Reserve. As discussed in the Waterfront Plan, maritime 
industry uses may include waterbome commerce and navigation and maritime support uses such as 
equipment storage and warehousing uses. As with the Industry Group components, compliance with 
NPDES permit conditions by developers on unprogrammed Port lands would minimize potential water 
quality degradation associated with stormwater runoff. 

Program-level water quality impacts associated with maritime uses are described in detail in the 
Waterfront Land Use Plan EIR (see pp. 586-589 of the Final EIR) and are summarized briefly here. Any 
shipping or boating activity would involve handling and storage of chemicals that could be discharged to 
surface waters. Potential pollutant sources include fuels, bilge water, boat cleaning and maintenance 
materials, sewage from boats and miscellaneous debris. Maritime uses could also increase the potential 
for fuels spills to the Bay. However, as described in the Waterfront Land Use Plan EIR, there are 
numerous regulations in place to protect water quality impacts associated with maritime uses. These 
include: federal Oil Pollution Act and California Oil Spill Response Act, RWQCB and U.S. Coast Guard 
permits for discharges from ships or boats, and NPDES permits for runoff from ship and boat repair 
facilities. Compliance with these regulations would minimize the potential for water quality degradation 
associated with maritime uses. Therefore, long term water quality impacts associated with maritime uses 
would be considered less than significant with mitigation. 



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Construction Impacts 

Construction of the various project components could affect water quality due to grading and 
earthmoving activities, use of fuels and other chemicals for construction equipment, and demolition and 
construction in proximity to the Bay. 

Grading and earthmoving activities would result in exposure of soil during construction and could result 
in erosion and excess sediments carried in stormwater runoff to surface waters. In addition, construction 
activities would also likely require temporary on-site use and storage of vehicles, fuels, wastes and other 
pollutant sources; if improperly handled, these pollutants could also be transported in stormwater runoff 
to surface waters. For projects with construction sites greater than five acres, the project sponsor would 
be required to obtain coverage under the statewide General Permit for Stormwater Discharges Associated 
with Construction Activity described above in the Setting section. These requirements would potentially 
apply to future Port development at Pier 70 and the Piers 90-94 backlands, as well as to Industry Group 
project components including Mission Valley Rock, British Pacific Aggregates, and Coach USA, all of 
which would occupy more than five acres, although the areas to be disturbed through grading or 
excavation could be considerably smaller and none of these components would require a substantial 
volume of earthmoving. Depending on the construction schedule for the various projects, the remaining 
project components under five acres in size may also be required to comply with similar regulations, 
since it is anticipated that Phase II construction stormwater requirements will be in place by August 
2001. 

Compliance with these regulations and NPDES permit conditions, including development and 
implementation of a site-specific Stormwater Pollution Prevention Plan, would minimize the potential 
for water quality degradation. The SWPPP would typically be required to indicate all pollutant sources 
within the construction area and to identify best management practices to prevent discharge of pollutants 
into stormwater. However, due to the uncertain timing of construction schedules and the Phase 11 
construction stormwater requirements, a mitigation measure would require that all proposed construction 
sites under the Industry Group projects, regardless of size, prepare and implement a SWPPP, in order to 
minimize construction water quality impacts (see Mitigation Measure D-l,p. 149). Therefore, with 
compliance of NPDES General Permit requirements for sites over five acres and with implementation of 
proposed mitigation measures for sites under five acres, water quality impacts associated with 
construction activities would be considered less than significant. 

Water quality impacts associated with demolition and construction in proximity to the Bay are discussed 
in the Waterfront Land Use Plan EIR. Construction activities located on or adjacent to the Bay would 
result in increased potential for spills and for construction materials or debris to enter the Bay and affect 
water quality, particularly if construction activities occur on windy days. Implementation of 
improvement measures identified in the Waterfront Land Use Plan EIR would minimize the potential for 
these impacts and are presented in Chapter IV of this report. Thus, implementation of these measures in 
conjunction with the SWPPP under the NPDES permit requirements discussed above would reduce 
potential water quality impacts to less than significant. 



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Water quality effects related to construction of the Illinois Street bridge are discussed in Section III.F, 
Biological Resources, on p. 139. 



REFERENCES - Hydrology and Water Quality 

California Regional Water Quality Control Board, Region 2, Final Regional Toxic Hot Spot Cleanup 
Plan, March 1999. 

California Regional Water Quality Control Board, Region 2 (RWQCB), Water Quality Control Plan for 
the San Francisco Bay Basin, 1995. 

California Regional Water Quality Control Board, National Pollutant Discharge Elimination System 
(NPDES) Permit No. CA0038610, City and County of San Francisco Bayside Wet Weather 
Facilities and NPDES Permit No CA0037664, reissuing Waste Discharge Requirements for City 
and County of San Francisco, Southeast Water Pollution Control Plant, 1994. 

Lundgren, Leslie, San Francisco Public Utilities Commission, personal communication, September 11, 
2000 

Medbery, Steve, Memorandum to Todd Cockbum regarding Mission Bay Stormwater Concerns, dated 
May 23, 1997 

San Francisco Estuary Institute, Regional Monitoring Program for Trace Substances, 1996 Annual 
Report, 1997. 

San Francisco Public Utilities Commission, Clean Water Program, Bayside Cumulative Impact Analysis, 
prepared by Chris Phanartzis, Hydroconsult Engineers, and Beth Goldstein, PUC, Draft, 
February 1998. 

State Water Resources Control Board, Industrial Activities Stormwater General Permit. Available at 
www.swrcb.ca.gov/stormwtr , 1997. 

State Water Resources Control Board, 1999, National Pollutant Discharge Elimination System (NPDES) 
General Permit for Stormwater Discharges Associated with Construction Activity (General 
Permit). Available at www.swrcb.ca.gov/stormwtr 

E. HAZARDOUS MATERIALS 

SETTING 

The assessment focuses on hazardous materials that may be encountered during construction including 
hazardous materials in the soil, solid waste disposal facilities, hazardous building materials, and 
abandoned hazardous wastes. The analysis is based on information from the following: 



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• A regulatory database search to identify known environmental cases within or adjacent to each of the 
proposed project sites (VISTA Information Solutions, 2000); 

• Review of Port of San Francisco, San Francisco Department of Public Health, and San Francisco 
Department of Public Works Reports; and 

• Visual site reconnaissance (Orion, 2000). 
REGULATORY SETTING 

Hazardous materials and hazardous wastes are subject to numerous federal, state, and local laws and 
regulations intended to protect health and safety. The overall regulatory framework for hazardous 
materials is discussed in Appendix F. Three San Francisco regulations from the Public Health Code 
applicable to the Southern Waterfront projects are summarized below: "Analyzing the Soil for 
Hazardous Wastes," the Hazardous Materials Ordinance, and the Hazardous Waste Ordinance. 

Analyzing the Soil for Hazardous Wastes 

In 1986, the City and County of San Francisco first established legislation known as the Maher 
Ordinance that required the investigation of hazardous wastes in soil at construction sites as a 
prerequisite for certain building permits. These regulations have since been codified in Article 20 of the 
San Francisco Public Works Code (in 1986) and Article 22A of the San Francisco Public Health Code (in 
1999)."^^ Article 22A of the Public Health Code is applicable to projects that include the disturbance of 
more than 50 cubic yards of soil and: 

(1) are located bay ward of the historic high tide line (i.e., in an area of Bay fill), as designated on an 
official City map; or 

(2) are located in other areas of the City designated for investigation by the Director of the Department 
of Public Health. These areas would include locations where the Director has reason to believe that 
hazardous wastes may be present in the soil. 

The regulations take effect at the time of the building permit application and impose the following major 
requirements on proposed developments: 

• Preparation of a site history report to describe past site uses and identify whether the site is listed as a 
hazardous waste site pursuant to state or federal regulations; 

• Implementation of a soil investigation to evaluate the potential presence of hazardous wastes in the 
soil; 

• Preparation of a soil analysis report that evaluates the results of chemical analysis of the soil 
samples; 

• Preparation of a site mitigation report, if contamination is identified, assessing potential 
environmental and health and safety risks and recommending measures to mitigate the risks; 



The requirements of both articles are similar. Only Article 22A of the Public Health Code is referred to in subsequent 
references in this document. 



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• Preparation of a certification report stating that either (1) no hazardous wastes present in the soil 
present an unacceptable risk and that no mitigation measures are required; or (2) all mitigation 
measures recommended in the site mitigation report have been completed and that completion of the 
mitigation measures has been verified through follow-up soil sampling and analysis, if required. 

The site history report and the soil analysis report must be prepared by knowledgeable, certified 
professionals and provide information on historic and current hazardous waste contamination at the 
property to be developed. The site history report is submitted to the San Francisco Department of Public 
Health. The soil analysis report is submitted to the San Francisco Department of Public Health, 
California Department of Toxic Substances Control, and the California Regional Water Quality Control 
Board, San Francisco Bay region. If the soil sampling and analysis report or the site history report 
indicate that the site proposed for development is listed on the National Priorities List or the list of 
California Hazardous Substances Account Act release sites, the applicant must certify that any site 
mitigation required by a federal or state agency has been completed. 

Article 22A protects the health and safety of the City's workers, residents, and occupants from risks 
associated with hazardous wastes in the soil by requiring a site assessment and mitigation of any risks 
identified as a condition for construction of a planned project. All of the proposed sites in the Southem 
Waterfront project are located bayward of the historic high tide line and would be subject to the 
requirements of Article 22A if construction of the project would include the disturbance of more than 
50 cubic yards of soil. 

Hazardous Materials Ordinance 

The Hazardous Materials Ordinance (Article 21 of the San Francisco Public Health Code) provides for 
safe handling of hazardous materials in the City. In accordance with this ordinance, any person or 
business that handles, sells, stores, or otherwise uses hazardous materials in quantities exceeding 
specified threshold, is required to obtain and keep a current hazardous materials certificate of registration 
and implement a hazardous materials plan submitted with the registration application. 

The Hazardous Materials Ordinance helps protect the health and safety of the general community and of 
emergency response personnel, such as fire fighters and paramedics. Data on hazardous materials use 
are stored in a City-wide computer system and can be made available to emergency responders. The 
information assists emergency responders to assess and resolve hazardous materials incidents quickly 
and safely. Inspections are performed by the City every one to two years or upon complaint. 

The Hazardous Materials Ordmance helps San Francisco busmesses to satisfy requirements of hazards 
communication and of community right-to-know laws. The registration process also helps businesses 
inventory and reduce the amounts of hazardous materials stored and hazardous wastes produced, and 
reduces overall risks posed to the community by these materials. 

Under the Hazardous Materials Ordinance, the Department of Public Health also permits underground 
storage tanks, oversees the closure of underground storage tanks and hazardous materials establishments. 



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and oversees the investigation of unauthorized releases of hazardous materials or petroleum products 
from underground storage tanks. 

Hazardous Waste Ordinance 

The Hazardous Waste Ordinance (Article 22 of the San Francisco Public Health Code) provides for safe 
handling of hazardous wastes in the City. The ordinance incorporates the state requirements for 
hazardous waste described in Section 6.5 (Hazardous Waste Management) of the California Health and 
Safety Code as well as the accompanying regulations found in CCR Title 22. 

POTENTIAL SOURCES OF HAZARDOUS MATERIALS AND HAZARDOUS BUILDING 
MATERIALS AT PROPOSED PROJECT SITES 

This section describes existing site conditions in terms of potential sources of hazardous materials that 
may affect development at the proposed project sites. Potential sources of hazardous materials at each of 
the proposed project sites include the following: 

• soil or groundwater that have been affected by chemical releases from past or present site uses, 

• migration from chemical releases in soil or groundwater at nearby sites, 

• abandoned hazardous materials, 

• existing permitted uses of hazardous materials, including underground and above-ground storage 
tanks, and 

• hazardous building materials. 

If hazardous materials were present in the soil or groundwater at a site, remediation of these materials 
could be required. The need for site remediation would be determined by the regulatory agency 
providing oversight for the site on the basis of the types and concentrations of chemicals present. A risk 
assessment may be conducted to determine acceptable levels of chemicals to be left in place based on the 
future land use of the property. In addition, if hazardous materials were present, construction workers or 
the public could be exposed to hazardous materials during construction and there could be special 
handling requirements for any soil excavated from the proposed project sites. 

Existing permitted uses of hazardous materials are well regulated to ensure safe handling of these 
materials. However, these sites are potential sources of hazardous substances to the soil and/or 
groundwater because of incidental leakage or spillage that may have gone undetected. 

Hazardous building materials are included in this discussion because some project components would 
involve demolition or renovation of existing structures. Some building materials conrunonly used in 
older buildings could present a public health risk if disturbed during an accident or during demolition of 
an existing building. These materials include asbestos, electrical equipment such as transformers and 
fluorescent light ballasts that contain polychlorinated biphenyls (PCBs), fluorescent lights containing 
mercury vapors and lead-based paints. Asbestos -and lead-based paint may also present a health risk to 



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existing building occupants if they are in a deteriorated condition. If removed during demolition of a 
building, these materials would also require special disposal procedures. 

In addition, this section describes three general sources of hazardous materials in the Southern 
Waterfront project area: fill material, two former solid waste disposal facilities, and Islais Creek. Fill 
used in the development of San Francisco's waterfront is known to contain hazardous materials. There 
are two former solid waste disposal facilities within the project area. One of these has been closed under 
regulatory requirements and the other is undergoing closure. Regulatory requirements for closure are 
described. A summary of hazardous materials conditions regarding Islais Creek is also presented 
separately because conditions within this creek could affect more than one project site. 

Methodology 

To assess the potential for hazardous materials to be present in the soil or groundwater, reports available 
through the Port of San Francisco and the San Francisco Department of Public Works as well as 
underground storage tank reports available at the San Francisco Department of Public Health, Local 
Oversight Program were reviewed in 1994 to identify known environmental conditions within the Project 
Area as part of the San Francisco Waterfront Land Use Plan EIR (Camp Dresser & McKee, 1998; 
Crosby & Overton, 1989; ERM-West, 1990; Geo/Resource Consultants, 1990; Orion, 2000; Port of 
San Francisco, 2000a; Port of San Francisco, 2000b; Port of San Francisco, 2000c; Port of San Francisco, 
1997a; Port of San Francisco, 1997b; Port of San Francisco, 1996; Port of San Francisco, undated; SCA 
Environmental, Inc., 1998; RWQCB, 2000; San Francisco Department of Public Health, 2000; 
San Francisco Department of Public Works, 1991; Tetra Tech, 1998; Tetra Tech, 1997; Treadwell & 
Rollo, 2000a; Treadwell & Rollo, 2000b; Treadwell & Rollo, 1999; VISTA Information Solutions, 
2000). To update information for this assessment, reports available through the Port of San Francisco 
were reviewed in February 2000 and a regulatory database search was conducted to identify known 
environmental cases within or adjacent to the project sites. 

A database search was conducted for the project to identify three categories of sites in the project areas 
that may be affected by hazardous materials: (1) sites with permitted underground or above-ground 
storage tanks, (2) sites permitted to handle hazardous wastes under the federal Resource Conservation 
and Recovery Act (RCRA), and (3) known environmental cases (VISTA Information Solutions, 2000). 
Appendix F presents the name and date of each database reviewed for this evaluation. A summary table, 
listing those sites of concern identified by the database review, is also provided in Appendix F. 

Sites permitted to handle hazardous wastes under RCRA and sites with permitted underground or above- 
ground storage tanks are approved to handle hazardous substances. Because the use and handling of 
hazardous materials at permitted sites are subject to strict regulation, the potential for a release of 
hazardous materials from these sites is considered low. Consequently, permitted RCRA and underground 
and above-ground storage tank sites are identified only if they are located within a planned project site. 



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Those sites suspected of releasing hazardous materials or that have had cause for hazardous materials 
investigations are identified on regulatory agency lists and are referred to as environmental cases. 
Identification of hazardous materials at these sites is generally due to site disturbance activities such as 
removal of an underground storage tank, a spill of hazardous materials, or excavation for construction. 
To evaluate the potential for hazardous materials in the soil at each of the proposed project sites, this 
section identifies environmental cases within the boundaries of each proposed project site as well as 
adjacent environmental cases which could impair soil quality within the proposed project site. 

General Sources of Hazardous Materials 
Fill Materials 

Prior to human settlement, most of the Southern Waterfront was part of the shallow margins of 
San Francisco Bay. Beginning in the 1850s, the waterfront was gradually filled with brick, wood, metal 
fragments, concrete, other rubble, debris, and sand. The fill along the Bay margins commonly contains 
polynuclear aromatic hydrocarbons (PNAs), heavy metals, oil and grease, and volatile organic 
compounds (VOCs), and this is one of the reasons for enactment of San Francisco's Maher Ordinance. 
All of the proposed project sites are underlain by fill. 

Landfill Closures 

Areas at Pier 94 and Pier 70 were filled by the Port in the late 1960's and early 1970's. These areas were 
designated as Class III landfills (non-hazardous solid waste) by the Regional Water Quality Control 
Board (RWQCB) and in 1987 they became subject to closure orders by the RWQCB. In accordance with 
the closure orders, the Port of San Francisco has monitored groundwater quality at these solid waste 
disposal sites on a quarterly basis and reports the results annually to the RWQCB. The status of 
groundwater monitoring and closure of these facilities is further described below. 

Islais Creek Area 

The Islais Creek Area is included on the federal Comprehensive Environmental Response, 
Compensation, and Liability Information System (CERCLIS) list, on the basis of oily wastes, solvents, 
and landfilling activities. No further remedial action is planned for this site. The Islais Creek area 
between Cargo Way and Amador Street is also identified in the Calsites database (the state equivalent of 
the CERCLIS database). Information available from the database review indicates that this is a former 
Annual Work Plan site that has been referred to the Regional Water Quality Control Board. Two spills 
were reported in the ERNS database in the Islais Creek area (VISTA Information Solutions, 2000). 

Industry Group Project Component Sites 

Known hazardous materials conditions at each of the Industry Group project sites are described briefly 
below and are summarized in Table 21. Additional detail regarding these conditions is provided in 
Appendix F. 



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in. ENVreONMENTAL SETTING AND IMPACTS 



E. HAZARDOUS MATERIALS - SETTING 



A soil investigation was conducted in the western portion of Pier 92 in 1999 to comply with the 
requirements of Article 22A (Treadwell & Rollo, 1999). Based on that investigation and on the various 
document and site reviews conducted for this SEIR, hazardous conditions identified at Industry Group 
sites include elevated concentrations of total and soluble lead in the soil at the proposed Bode Gravel 
ready-mix plant site (part of a proposed joint leasehold with Mission Valley Rock), where fuel storage 
tanks were once located. These levels mean that any soil excavated could be classified as a hazardous 
waste and would require special handling. Soil from one location contained total zinc at a concentration 
greater than the total threshold limit concentration.'*^ Hydrocarbons and other volatile organic 
compounds were identified in the soil, but at levels below those for which any remediation would be 
required prior to industrial reuse. Hydrocarbons and various metals were found in groundwater, but 
because the groundwater in this area is not used as a drinking water supply, no remediation would be 
required. In addition to subsurface contamination, there is a large soil stockpile at Pier 92. Sampling 
indicates that if this soil required disposal, more than half of the pile would be considered hazardous 
waste under state regulations because of concentrations of lead and other metals. 

Although no site survey has been conducted for the site of Mission Valley Rock's proposed aggregate 
import terminal and asphalt plant, conditions are likely similar to those at the Bode site because of the 
similarity of prior uses on the two sites and the proximity of nearby sources of potential contamination. 
A fuel oil tank was removed from the Mission Valley Rock site in 1998, at which time soil 
contamination was noted. The excavation site was lined with an impermeable barrier and the excavated 
soil replaced. However, the San Francisco Department of Public Health will require additional remedial 
action (not completed as of mid-2000). At the adjacent Pier 90 site, where the former grain silos are 
proposed for use by ISG Resources as a fly ash import and storage facility, a limited Phase I 
investigation in 1989 revealed low levels of benzene, toluene, ethylbenzene and xylenes, thought to be a 
result of surface spills from vehicles. 

Pier 94, where British Pacific Aggregates (BPA) proposes an aggregate shipping terminal, consists of fill 
including soil and rock, construction waste, dredge spoil, and miscellaneous refuse. Part of Pier 94 is 
subject to landfill closure requirements imposed by the Regional Water Quality Control Board. 
However, the paved portion, where the BPA facility would be located, is outside of the portion of the 
landfill subject to closure requirements. 

No known site assessments or investigations have been conducted at the Pier 80 site where RMC Pacific 
Materials proposes a concrete ready-mix plant. Several fuel leaks have been identified in the vicinity, 
and two underground tanks have been removed nearby. Remedial action has occurred at all but one of 
the four sites noted. 



A waste is considered hazardous on the basis of toxicity if it contains the specified substance at a concentration greater than 
the regulatory levels specified, in Title 22 of the California Code of Regulations, Section 66261 .24(a)(2). These regulatory 
levels include the Total Threshold Limit Concentration (TTLC) and the Soluble Threshold Linut Concentration (STLC). 



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E. HAZARDOUS MATERIALS - SETTING 



No site assessments are known to have occurred at the other two Industry Group sites. Waste 
Management's proposed construction materials recycHng facihty at Pier 70 and Coach USA's proposed 
bus storage depot at Pier 96. Both of these facilities would use existing buildings, where materials such 
as asbestos and lead-based paint could be present. The only identified instance of potential subsurface 
contamination related to either of these sites was as gasoline leak at an underground storage tank near 
Pier 96 in 1996; soil was excavated and disposed of and this case was reported closed. (See the further 
discussion concerning Pier 70 on p. 126, under "Potential Future Port Development Projects." 

Illinois Street Intermodal Bridge 

The review performed for this EIR did not identify any site assessments or site investigations performed 
for Islais Creek in the area planned for the intermodal bridge. The Islais Creek area was identified as an 
environmental case in several environmental databases, as described in the Islais Creek Area discussion 
on p. 1 19. 

Future Port Development Sites 

Known hazardous materials conditions at the future Port development sites are described briefly below 
and are summarized in Table 22. Additional detail regarding these conditions is provided in Appendix F. 

Dredge Material Handling Site 

As described above in the discussion of British Pacific Aggregates, Pier 94, where the Port proposes its 
expanded dredge material storage operation, consists of a former landfill subject to closure requirements 
imposed by the Regional Water Quality Control Board. Pier 94 is an approximately 96-acre partially 
paved site created by placement of inert and non-inert fill material to construct a marine shipping 
terminal. The fill is composed of a variety of materials including clayey soil and rock fragments, 
construction waste mixed with soil, dredge spoil, and miscellaneous refuse. A variety of earthen 
materials and debris, including concrete, asphalt, and metal debris and household garbage) was placed 
over the site after fill placement ceased. Groundwater at Pier 94 is monitored in accordance with Closure 
Order No. 87-061 from the Regional Water Quality Control Board (RWQCB) (Port of San Francisco, 
1997a). 

In 1991, a preliminary closure plan was submitted to the RWQCB for the 14-acre section of Pier 94 that 
is subject to the closure order. The plan addressed reconstruction and grading, final cover, precipitation 
and drainage control, shoreline stabilization, geotechnical stability, and settlement. The Port has not 
received comments from the RWQCB on the preliminary plan. 



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ni. ENVIRONMENTAL SETTING AND IMPACTS 



E. HAZARDOUS MATERIALS - SETTING 



Various options are under consideration for closure of the landfill (Tetra Tech, 1997) and selection of the 
appropriate option could depend on the intended reuse of the site. The Port is currently compiling and 
reviewing groundwater monitoring data for the landfill to further assess closure requirements as required 
by the Regional Water Quality Control Board (Port of San Francisco, 2000a). The designs, grading 
plans, material and construction specifications, schedules and cost estimates would all need to be 
substantially revised prior to submitting the final closure plan for RWQCB approval (Port of 
San Francisco, 1997b). 

Implementation of the Port's dredge material expansion project could require that the area to be used be 
capped with an impermeable barrier to prevent decant water from draining out of dredged material and 
into and through the former landfill. Alternatively, the Port could perform further testing that might 
demonstrate, to the satisfaction of the RWQCB, that infiltration of seawater through the former landfill 
would not adversely affect water quality in the Bay. Thus, implementation of the dredge material 
expansion project in compliance with RWQCB regulations would result in a less-than-significant effect. 

Other Port Lands 

Pier 70 and surrounding areas contain a solid waste landfill and numerous dilapidated old buildings. 
There has been heavy industrial use, including ship repair, at Pier 70 for more than 100 years. Previous 
land uses and underground storage tanks within this area have affected soil and/or groundwater quality. 
In addition, there are several existing land uses that involve the use of hazardous materials. There is also 
a three-acre solid waste disposal site that includes four shipyard slips. The site was constructed of 
demolition debris from previously existing structures mixed with earthen material. Deposition of fill 
material was completed, and the site was capped with asphalt in 1971. On the basis of groundwater 
monitoring results, the waste material does not pose a threat to water quality and does not require 
additional characterization or management as a landfill (RWQCB, 2000) 

A Phase I site assessment for the Pier 70 area (Tetra Tech, 1998) identified a number of historic 
underground and above-ground storage tanks, many of which have been removed and some of which 
were reported to have leaked. Remediation has been conducted at several sites. The Phase I report also 
identified other potential sources of hazardous materials, including: 

• Soil in the vicinity of Building 6 was reported to contain copper, lead, zinc, and PNAs. Additional 
sampling was recommended and there were plans to clean the inside of Building 6. There were 
indications that hazardous waste may have been left in Building 6; 

• Building 12 may contain concentrations of lead and cadmium; 

• There are reported releases of heavy metals from former site activities to areas south of the mixed 
use opportunity area; and 

• There were reported spills of hazardous materials in the old Convoy Company facility in 1987. The 
DTSC recommended catch basins beneath drums used for oils, hydraulic fluids, and antifreeze. 
Documentation reviewed did not show the location of this facility, but it is estimated to be to the east 
of Building- 113. 



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E. HAZARDOUS MATERIALS - SETTING 



Activities at facility that formerly operated in the northwest comer of Pier 70, B & C Metals, could have 
affected soil and/or groundwater quality within the Mixed Use Opportunity Area. In 1996, soil identified 
as a hazardous waste on the basis of lead concentrations was removed from two paved boat ramps 
adjacent to B & C Metals, where vessels had been dismantled (Port of San Francisco, 2000c). B&C 
Metals used many hazardous materials including lubricating oils and flammable gasses, but 
documentation from 1997 indicates that B & C did not register them or comply with hazardous materials 
storage regulations. In addition, some vessels accepted at the facility contained asbestos containing 
materials and lead based paint although the employees were not trained to identify and manage these 
materials. In 1997 five vessels were stored at Pier 70 and three of these vessels contained asbestos 
containing materials and lead-based paint (Tetra Tech, 1998). The Port reports that four of these vessels 
have been removed and the one that remains is not believed to contain asbestos (Port of San Francisco, 
2000b). 

The vacant buildings within Pier 70 are in a generally dilapidated condition. Based on their age 
(constructed prior to 1950), they would likely contain hazardous building materials, including lead-based 
paint. Asbestos has been identified in several buildings. There are electrical transformers remaining at 
Pier 70 with PCB containing oil (Tetra Tech, 1998). These transformers are typically surveyed and 
retrofitted on a project specific basis and it would be necessary to conduct a survey of any buildings 
planned for demolition or renovation to determine if any PCB containing electrical equipment remains 
within a specific building. Mitigation Measure E.4, p. 152, would require such surveys. A cleanup of 
illegally stored hazardous materials was completed at Building 6 in 1983. 

At the Western Pacific Property, lead and arsenic were identified in the soil at concentrations exceeding 
the total threshold limit concentration. Hydrocarbons and metals were detected in soil samples, and the 
groundwater was found to be affected by petroleum products, polynuclear aromatic hydrocarbons, 
volatile organic compounds, and lead. In addition, the off-shore sediments were found to contain 
polynuclear aromatic hydrocarbons and metals (Dames & Moore, 1989). In accordance with a request 
from the Regional Water Quality Control Board, a site remediation was conducted in 1993 and 1994 
which involved capping the site to reduce the potential for infiltration and runoff. As part of this 
remediation, the following activities were conducted (Levine-Fricke, 1994): regrading of the shoreline 
slope; placing a geotextile fabric to inhibit migration of fines to the bay; installing riprap slope 
protection; constructing a 10-foot wide gravel sediment trap behind the riprap; regrading a 50-foot wide 
strip behind the sediment trap; placing a geotextile on the subgrade and paving over the geotextile; and 
constructing an 80-foot wide gravel transition zone behind the paved area. 

The San Francisco Municipal Railway plans to use the western portion of this property for a light rail 
vehicle maintenance and operations facility and has conducted a Site Characterization/Corrective 
Measures study to comply with Article 22A. The Port is currently reviewing the data for the eastern 
portion of the site planned for Port use, and is conducting a risk assessment for various reuse scenarios. 
The choice of uses would depend partially on the results of the risk assessment (Port of San Francisco, 
2000a). A draft Risk Assessment report found all're-use scenarios evaluated, except that for single- 



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E. HAZARDOUS MATERIALS - SETTING 



family housing, to be below accepted risk criteria; no single-family housing is proposed for the Western 
Pacific site. The database review identified this site in the North Bay County Toxic List, but no further 
information was available (VISTA Information Solutions, 2000). 

The review performed for this EIR did not identify any site assessments or site investigations performed 
for the Pier 90 to 94 backlands. A portion of the backlands being considered for development overlap 
the regulated portion of the landfill at Pier 94 (described under British Pacific Aggregates, above). 
Current activities at this site include Specialty Crushing, Tide Water Sand and Gravel (Hanson 
Aggregates), and the Port of San Francisco Marine Terminal. Specialty Crushing and Tide Water Sand 
and Gravel are located atop the regulated portion of the landfill. 



IMPACTS 



SIGNIFICANCE CRITERIA 

The City has not formally adopted significance standards for hazard impacts, but it generally considers 
that implementation of the Southern Waterfront project would have a significant hazards effect if it were 
to: 

• involve a substantial risk of accidental explosion or release of hazardous substances (including, but 
not limited to, oil, pesticides, chemicals, or radiation); 

• expose people to existing sources of potential hazards including hazardous materials; 

• create a public health hazard or potential public health hazard; or 

• interfere with an emergency response plan or emergency evacuation plan. 

Definition, identification and determination of threshold levels of hazardous materials and wastes are 
provided in the Title 40 of the Code of Federal Regulations (40 CFR) and in Title 22 of the California 
Code of Regulations. In accordance with these regulations, a hazardous waste is a substance or 
combination of substances, which because of its quantity, concentration, or physical, chemical, or 
infectious characteristics may pose a substantial threat, or potential hazard to human health, or 
environment, when improperly treated, stored, transported, disposed of, or otherwise managed. 
Determination of "substantial" hazard or "insignificant" levels of hazardous materials is performed by 
the regulatory agencies on a case-by-case basis, depending on the proposed uses, potential exposure, and 
degree and type of hazard. 

It is not anticipated that any of the project components would interfere with emergency response or 
evacuation plans. The Industry Group components would generally be constructed on sites that would be 
relatively isolated (east of Third Street) and therefore would not substantially interfere with emergency 
routes. Furthermore, the Industry Group components would not result in large concentrations of people, 
as employment would be relatively small at each component (most of the sites would be devoted to 
materials processing and storage). Some of the potential future Port developments (office, research and 
development, retail uses) could involve large numbers of employees. However, buildings that would 



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m. ENVIRONMENTAL SETTING AND IMPACTS 

E. HAZARDOUS MATERIALS - IMPACTS 

house such uses would be constructed in accordance with appUcable building and fire codes, with plans 
to be reviewed by the Port' s fire marshal, which would minimize risks due to any potential inadequacies 
in emergency response routes. 

IMPACT ANALYSIS-INDUSTRY GROUP COMPONENTS 
Accidental Release of Hazardous Materials or Petroleum Products 

Projects at Bode Gravel, Mission Valley Rock, Waste Resources Technologies, and Coach USA would 
include above-ground or underground storage tanks for the storage of fuel products. Above-ground fuel 
tanks may also be required for British Pacific Aggregates and ISG Resources. The proposed Mission 
Valley Asphalt Plant would also include the above-ground storage of asphalt cement. 

If a leak occurred from an on-site fuel tank, the material stored in the tank could affect soil, groundwater, 
or Bay water quality. However, businesses that store petroleum products above ground would be 
required to comply with the requirements of the City's Hazardous Materials Ordinance which includes 
the requirements for secondary containment and preparation of a Spill Prevention Control and 
Countermeasure Plan to specify emergency procedures to be followed in the event of a spill. When 
stored above-ground, fuels are commonly stored in an above-ground tank similar to a Convault system 
with secondary containment that is virtually leak-proof. Regulations governing underground storage 
tanks (USTs) require a separate permit to operate a UST and include an inspection and monitoring 
requirement by the Department of Public Health (DPH). Further, all establishments that store fuel on- 
site, whether in above-ground or underground tanks, must register with DPH. 

In the unlikely event that a leak or tank rupture did occur, the spill would likely be contained within the 
secondary containment system for the tank. Secondary containment and implementation of emergency 
response procedures would minimize potential exposure of site personnel and the public to petroleum 
vapors as well as protect the site from potential environmental contamination. Compliance with existing 
regulations regarding storage and spill protection would therefore render this impact less than significant. 

Hazardous Materials in Soil 

Construction for the Bode Gravel and Mission Valley Rock projects would involve the excavation of 
more than 50 cubic yards of soil. If hazardous materials are present in the exposed soil or groundwater, 
there could be a public health impact. During construction, workers and the public could become 
exposed to airborne contaminants and if hazardous wastes are left in the soil, site occupants could be 
exposed through normal operations unless mitigation measures are implemented. These potential 
impacts are mitigated through compliance with Article 22A "Analyzing the Soil for Hazardous Wastes." 
The following activities are required to comply with this article: 

• Preparation of a site history report; 

• Implementation of a soil investigation; 



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• Preparation of a soil analysis report; 

• Preparation of a site mitigation report; and 

• Preparation of a certification report certifying compliance with Article 22A. 

These activities have been completed for Pier 92 to the satisfaction of the San Francisco Department of 
Public Health through preparation of the site mitigation report. The site history report is summarized in 
the Setting, p. 122, and described further in Appendix F. A site mitigation plan has been prepared 
specifying measures that will be taken to mitigate risks to the site workers and public associated with the 
presence of lead in the soil at Pier 92 (Treadwell & Rollo, 2000b). The plan specifies the following: 

• Placement of part of the stockpiled soil in the lower portions of the site to bring the entire site up to 
final grade for the proposed project. Soil produced from excavation for utilities would be 
incorporated into this pile. Soil remaining after site grading would be placed on the western 
portion of Pier 92 after it is compacted and graded; 

• Use of dust control measures during excavation activities. These measures may include moisture 
conditioning or use of dust suppressants to reduce the exposure to contaminants in the soil; 

• Preparation of a health and safety plan specifying measures to protect site workers and the public 
from exposure to chemicals during excavation activities; 

• Installation of an asphalt or concrete cap to mitigate the potential for direct contact with the soil by 
future site users. The entire site would be covered by a structure or the cap; 

• Implementation of maintenance requirements to ensure that the long-term site mitigation measures 
(specifically capping the soil) will remain in effect during the site's use and occupancy period. 

The San Francisco Department of Public Health (DPH) approved the site mitigation plan in April 2000 
(SFDPH, 2000). As part of its approval, DPH noted that a certification report and maintenance report are 
required as part of the proposed project because of the elevated levels of lead that will remain in the soil 
beneath the cap. The planned maintenance measures specified in the site mitigation report to maintain 
the integrity of the cap and protect future site workers who may disturb the cap include: 

• Notify DPH of any proposed activity expected to disturb the integrity of the capping layer or soil 
thirty (30) calendar days before work commences. In cases of emergency, DPH shall be notified 
within 24 hours and work should commence in accordance with the mitigation measures described 
in the soil management plan. 

• Prepare a specific work plan that includes a description of the proposed construction activities, soil 
management plan, and health and safety plan. 

• Require any contractor or employee who disturbs the cap and is engaged in any excavation or earth 
movement at the property to comply with appropriate local, state, and federal regulations. 

• Require any contractor or employee engaged in any activities that involve penetrating the cap to 
repair the disturbed area as soon as is practical. 

• Control dust by wetting and protect the exposed or excavated soil from storm water run-on and 
run-off during the period of excavation, soil movement, or exposure. 



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• Determine by appropriate testing whether any excess material removed from the site is hazardous 
pursuant to state and federal hazardous waste criteria. This material must be managed in 
accordance with all appropriate regulations. 

• Provide DPH with a report that describes the maintenance activities related to the cap or 
excavation of soil. 

The Port and the operator of the site would be required to maintain the site mitigation plan, maintenance 
report, and maintenance records in a readily accessible on-site location. They would also be responsible 
for informing any employee or contractor who will perform below-grade construction of the 
environmental conditions, soil management concerns, and health and safety requirements stipulated in 
the soil management plan. Compliance with existing Article 22A regulations regarding site mitigation 
and site maintenance would therefore render this impact less than significant. 

In addition, remaining stockpiled soil at Pier 92 may require disposal if it cannot be used in construction 
projects. If disposed of off-site, the soil would probably be screened to remove large debris and tested to 
determine an appropriate disposal site. Soil from the stockpile may not be suitable for disposal at a solid 
waste landfill, and may require disposal as a California hazardous waste due to its soluble lead content. 
A detailed description of soil disposal requirements is presented in Appendix F. With compliance with 
existing waste disposal regulations, this impact would be less than significant. 

In addition to the Bode and Mission Valley Rock site, other Industry Group project components that may 
involve excavation of more than 50 cubic yards of soil would also be required to comply with 
Article 22A. Similarly, construction of the Illinois Street bridge would be subject to Article 22A should 
more than 50 cubic yards of excavation be required. Compliance with Article 22A procedures would 
reduce any potential impacts resulting from subsurface contamination to a less-than-significant level. 
For sites not subject to Article 22A because they would involve excavation of less than 50 cubic yards, 
the potential for exposure to subsurface hazardous materials is very small, because the amount of soil to 
be moved would be negligible (the equivalent of a 37-foot by 37-foot square one foot deep). 

Release of Chemicals from Construction Equipment 

During construction at each of the proposed project sites there is the potential that construction 
equipment could accidentally release petroleum products such as oil, grease, or fuel which could enter 
Islais Creek or the Bay and degrade water quality. This impact is judged less than significant because it 
is mitigated by compliance with existing laws. As discussed in Water Quality (Section III.D), where 
construction activities are adjacent to a waterway, and where more than five acres would be disturbed 
through grading or excavation, the construction contractor(s) would be required to prepare and 
implement a Spill Prevention, Control, and Countermeasure Plan as well as a Storm Water Pollution 
Prevention Plan. Construction contract specifications would include strict on-site handling rules to keep 
construction and maintenance materials out of receiving waters. The plan would include measures to be 
taken in the event of an accidental spill. This impact would be less than significant with mitigation (i.e. 
compliance with existing requirements for a spill* prevention control and countermeasure plan, described 



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in Mitigation Measure E.l, and with preparation of a storm water pollution prevention plan described in 
Mitigation Measure D.l). 

Hazardous Building Materials 

Hazardous building materials may be encountered during renovation or demolition of existing buildings. 
Exposure to hazardous building materials (if present) could occur as a result of these activities. Potential 
hazardous building materials that could be present include asbestos, lead-based paint, PCBs, and 
fluorescent lights containing mercury vapors. 

Asbestos 

If friable or nonfriable asbestos is present, there is a potential for release of airborne asbestos fibers when 
the asbestos-containing materials are disturbed, unless proper asbestos abatement precautions are taken. 
Such a release could expose the public and construction workers to airborne asbestos fibers. 

Section 19827.5 of the California Health and Safety Code, adopted January 1, 1991, requires that local 
agencies not issue demolition or alteration permits until an applicant has demonstrated compliance with 
notification requirements under applicable Federal regulations regarding hazardous air pollutants, 
including asbestos. The Bay Area Air Quality Management District (BAAQMD) is vested by the 
California legislature with authority to regulate airborne pollutants, including asbestos, through both 
inspection and law enforcement, and is to be notified ten days in advance of any proposed demolition 
(defined as moving or dismantling or any structural member of a building), and any renovation in which 
more than 100 linear feet, 100 square feet, or 35 cubic feet of asbestos-containing material is to be 
removed. Notification includes the names, addresses and phone numbers of operations and persons 
responsible, including the contractor; description and location of the structure to be 
renovated/demolished including size, age and prior use, and the approximate amount of friable asbestos; 
scheduled starting and completion dates of demolition; nature of planned work and methods to be 
employed; procedures to be employed to meet BAAQMD requirements; and the name and location of the 
waste disposal site to be used. The District randomly inspects removal operations, hi addition, the 
District inspects any removal operations concerning which a complaint has been received. 

The local office of the California Occupational Safety and Health Administration (OSHA) must be 
notified if asbestos abatement is to be carried out. Asbestos abatement contractors must follow State 
regulations contained in 8 CCR 1529 and 8 CCR 341.6 through 341.14 where there is asbestos-related 
work involving 100 square feet or more of asbestos-containing material. Asbestos removal contractors 
must be certified as such by the Contractors Licensing Board of the State of California. The owner of the 
property where abatement would occur must have a Hazardous Waste Generator Number assigned by, 
and registered with, the California Department of Health Services. The contractor and the hauler of the 
material are required to file a Hazardous Waste Manifest that details the hauling of the material from the 
site and the disposal of the material. 



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Prior to renovation or demolition of any existing structures, the applicable project sponsor (Industry 
Group member) would be responsible for properly removing confirmed asbestos containing materials 
(see Mitigation Measure No. E.4, p. 152). Implementation of this measure and compliance with State 
asbestos regulations and procedures would ensure that any potential impacts due to asbestos would be 
reduced to a level of insignificance. 

Lead-Based Paint 

If lead-based paint is present and has delaminated or chipped from the surfaces of the building materials, 
there is a potential for the release of airborne lead particles during construction, renovation, or other 
activities that would disturb loose or peeling paint, unless proper lead abatement procedures are 
followed. Construction and renovation activities must comply with Chapter 36 of the San Francisco 
Building Code, Work Practices for Exterior Lead-Based Paint. Where there is any work that may disturb 
or remove lead paint on the exterior of any building built prior to December 31, 1978, Chapter 36 
requires specific notification and work standards, and identifies prohibited work methods and penalties. 

Chapter 36 applies to buildings or steel structures on which original construction was completed prior to 
1979 (which are assumed to have lead-based paint on their surfaces), where more than ten total square 
feet of lead-based paint would be disturbed or removed. The ordinance contains performance standards, 
including establishment of containment barriers that are at least as effective at protecting human health 
and the environment as those in the most recent Guidelines for Evaluation and Control of Lead-Based 
Paint Hazards promulgated by the U.S. Department of Housing and Urban Development. The ordinance 
also identifies prohibited practices that may not be used in disturbance or removal of lead-based paint. 
Any person performing work subject to the ordinance shall make all reasonable efforts to prevent 
migration of lead paint contaminants beyond containment barriers during the course of the work, and any 
person performing regulated work shall make all reasonable efforts to remove all visible lead paint 
contaminants from all regulated areas of the property prior to completion of the work. 

The ordinance includes notification requirements, contents of notice, and requirements for signs. 
Notification includes notifying bidders for the work of any paint-inspection reports verifying the 
presence or absence of lead-based paint in the regulated area of the proposed project. Prior to 
commencement of work, the responsible party (owner or contractor) must provide written notice to the 
Director of Building Inspection of the location of the project; the nature and approximate square footage 
of the painted surface being disturbed and/or removed; anticipated job start and completion dates for the 
work; whether the responsible party has reason to know or presume that lead-based paint is present; 
whether the building is residential or non-residential, owner-occupied or rental property; the approximate 
number of dwelling units, if any; the dates by which the responsible party has or will fulfill any tenant or 
adjacent property notification requirements; and the name, address, telephone number, and pager number 
of the party who will perform the work. (Further notice requirements include Sign When Contaminant is 
Required, Notice by Landlord, Required Notice to Tenants, Availability of Pamphlet related to protection 
from lead in the home. Notice by Contractor, Early Commencement of Work [by Owner, Requested by 
Tenant], and Notice of Lead Contaminated Dust or Soil, if applicable.) The ordinance contains 



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provisions regarding inspection and sampling, and enforcement, and describes penalties for non- 
compliance with the requirements of the ordinance. 

These regulations and procedures required as part of the San Francisco Building Code would ensure that 
potential impacts due to lead-based paint would be reduced to a level of insignificance. 

Polychlorinated Biphenyls (PCBs) and Fluorescent Light Tubes 

If PCBs are present in the building to be demolished, leakage could expose workers to unacceptable 
levels of PCBs (greater than 5 parts per million, based on Title 22, California Code of Regulations). 

Removal of fluorescent light tubes could result in exposure to mercury vapors if the lights are broken. A 
detailed description of hazardous building material abatement and disposal requirements is presented in 
Appendix F. 

The project sponsors would ensure that survey(s) for hazardous building materials is completed prior to 
renovations of an existing building, and that removal and disposal of transformers and light tubes, if 
required, is completed (see Mitigation Measure No. E.4, p. 152). This would reduce impacts related to 
hazardous building materials to a less-than-significant level. 



IMPACT ANALYSIS FOR FUTURE PORT DEVELOPMENT (PROGRAM-LEVEL) 

As described in the setting, site remediation was conducted in 1993 and 1994 for the Western Pacific 
Property, under direction from the Regional Water Quality Control Board, which included regrading of 
the shoreline slope; placing a geotextile fabric to inhibit migration of fines to the bay; installing riprap 
slope protection; constructing a 10-foot wide gravel sediment trap behind the riprap; regrading a 50-foot 
wide strip behind the sediment trap; placing a geotextile on the subgrade and paving over the geotextile; 
and constructing an 80-foot wide gravel transition zone behind the paved area. A subsequent draft Risk 
Assessment report found all re-use scenarios evaluated, except that for single-family housing, to be 
below accepted risk criteria; no single-family housing is proposed for the Western Pacific site. 

Impacts associated with the future development projects on Port lands would generally be comparable to 
those described above for the Industry Group project components. On a program level, these impacts 
would be considered less than significant through compliance with existing laws including Article 22A, 
the Hazardous Materials Ordinance, and the Hazardous Waste Ordinance, and hazardous materials 
abatement and disposal regulations. 

Potential impacts could include worker exposure to subsurface contamination (soil and groundwater), 
including unknown underground storage tanks; exposure of workers and/or the public to hazardous 
building materials; and accidental release of hazardous materials during project operations. Site-specific 
environmental review could be required for subsequent development projects on Port lands. 



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Future development on Port lands would likely occur in phases, meaning that there would be the 
potential for workers to occupy one building while an adjacent, potentially contaminated, site is under 
construction. Compliance with the provisions of Article 22A, where applicable, would ensure that 
effects on occupants of adjacent properties would be less than significant. 

With regard to the Pier 90-94 backlands, as noted in the setting, part of Pier 94 is subject to a Regional 
Water Quality Control Board (RWQCB) preliminary closure plan for 14 acres of a former landfill. The 
plan addressed reconstruction and grading, final cover, precipitation and drainage control, shoreline 
stabilization, geotechnical stability, and settlement. The Port has not received comments from the 
RWQCB on the preliminary plan. 

Various options are under consideration for closure of the landfill (Tetra Tech, 1997) and selection of the 
appropriate option could depend on the intended reuse of the site. The Port is currently compiling and 
reviewing groundwater monitoring data for the landfill to further assess closure requirements as required 
by the RWQCB (Port of San Francisco, 2000a). The designs, grading plans, material and construction 
specifications, schedules and cost estimates would all need to be substantially revised prior to submitting 
the final closure plan for RWQCB approval (Port of San Francisco, 1997b). Development in accordance 
with RWQCB regulations would avoid any potentially significant effects on the former Pier 94 landfill 
site. 



REFERENCES - Hazardous Materials 

California Regional Water Quality Control Board, San Francisco Bay Region (RWQCB), 2000. Order 
No. 00-030, Rescission of Waste Discharge Requirements in Order No. 87-060, City and County 
of San Francisco, San Francisco Port Commission, Pier 70 Class III Landfill. April 19. 

Camp Dresser & McKee, 1998. Underground Storage Tank Removal Report, Pier 92, San Francisco, 
California. September 25. 

Crosby & Overton, Inc., 1989. Muni/Pier 90 Investigation. December 29. (P-9) 

Dames & Moore, 1989. Final Draft Report, Phase II Site Characterization/Risk Assessment, Union 
Pacific Army Street Site, San Francisco, California. June 26. (P-11) 

ERM-West, Inc., 1990. Hazardous Materials Investigation of the Mariposa Facilities Project Area. July. 
(P-7) 

GeoResource Consultants, Inc., 1990. Final Data Compilation Report, Pier 70, San Francisco, California. 
January 2. 

Levine-Fricke, 1994. Completion of Shoreline Remediation Activities, Union Pacific Army Street Site, 
San Francisco, California. June 10. 

Orion Environmental Associates, 2000. Site visits by Mary McDonald on February 29 and March 3. 

Port of San Francisco, 1996. Underground Storage Tank Closure Documentation, Port of San Francisco. 
March 21. 



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Port of San Francisco, 1997a. 1996 Annual Groundwater Monitoring Report, Piers 70, 94, and 98, Port of 
San Francisco, California. June 23. 

Port of San Francisco, 1997b. Landfill Closure Requirements, Pier 94. Memo from Carol Bach to Nick 
La Rocco. June 24. 

Port of San Francisco, 2000a. Personal communication from Carol Bach to Mary McDonald of Orion 
Environmental Associates. February 16. 

Port of San Francisco, 2000b. Email from Carol Bach to Mary McDonald of Orion Environmental 
Associates. May 22. 

Port of San Francisco, 2000c. File review by Mary McDonald of Orion Environmental Associates. May 
24. 

Port of San Francisco, undated. Abandoned Waste. (P-20) 

San Francisco Department of Public Health (SFDPH), 2000. Letter to Berkeley Asphalt & Ready Mix, 
Bode Gravel Company, and Treadwell & RoUo re Proposed Batch Plant, Pier 92 - Amador Street, 
San Francisco, CA. April 6. 

San Francisco Department of Public Works, 1991. Inter-Bureau Memo from Stanley DeSouza to 
Manfred Wong. Pier 70 Soil/Groundwater Results from PACE Laboratories, Inc & Mariposa 
Facilities Project. January 22. 

SCA Environmental, Inc., 1998. Sunnmary Report: Asbestos and Lead-Based Paint Survey, Pier 70, 
Buildings 36, 40, 101, 104, and 109, 20 and Illinois Streets, San Francisco, California. May. 

Tetra Tech, Inc., 1997. Pier 94 Landfill Closure Plan Peer Review. September 22. 

Tetra Tech, Inc. 1998. Phase I Environmental Site Assessment for Pier 70, Mixed Use Opportunity Area, 
Comer of Illinois Street and 20* Street, San Francisco, California, 94107. August. 

Treadwell & Rollo, 1999. Environmental Site Assessment, Bode Gravel, Pier 92, Port of San Francisco, 
San Francisco, Califomia. August 12. 

Treadwell & Rollo, 2000a. Soil Stockpile Profiling, Pier 92 - Amador Street, San Francisco, Califomia. 
January 12. 

Treadwell & Rollo, 2000b. Site Mitigation Plan, Proposed Berkeley Asphalt/Bode Gravel Batch Plants, 
Pier 92, San Francisco, Califomia. March 29. 

VISTA Information Solutions, 2000. Site Assessment Plus Report. February 11. 



F. BIOLOGICAL RESOURCES 

This section focuses on potential impacts on biological resources that could result from construction of 
the proposed Illinois Street Bridge over Islais Creek. For information on other effects related to 
biological resources, please see the Waterfront Land Use Plan FEIR (Section IV.H, Biological Resources 
Setting, p. 244; Section V.H, Biological Resources Impacts, p. 548; and Section VI. H., Biological 
Resources Mitigation Measures, p. 653). Mitigation Measures from the Waterfront Land Use Plan FEIR 
are also included in Chapter IV of this SEIR. 



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SETTING 

Historically, Islais Creek intersected the band of tidal marshes and embayments between Candlestick 
Point and Coyote Point, carrying runoff from a number of small creeks in southeastern San Francisco. 
At present, it is a thoroughly industrialized urban waterway with a shoreline of predominantly creosoted 
timber pilings, rock revetment, concrete walls, and rubble. There are small amounts (about a hundred 
linear feet) of natural and weedy vegetation, including common pickleweed {Salicomia virginica) at the 
mean high tide level, and a small, narrow band of mudflat on the southern bank of the creek mouth, 
about 2,000 feet bayward of the proposed Illinois Street Bridge site. 

Wildlife in the vicinity of the proposed bridge construction project is limited to urbanized birds and 
mammals (e.g. starling [Stumus vulgaris] and Norway rats [Rattus norvegicus]. Nearby terrestrial 
habitat consists primarily of weeds on vacant sites with rubble and abandoned machinery, some 
ornamental plantings, and various structures. There is no habitat for any terrestrial species of concern. 
There are no wetland species of vegetation at the proposed bridge site. 

The aquatic habitat is only slightly more productive. At the site of the proposed bridge construction, the 
100-foot wide channel is about forty feet deep at MHW. The northern bank is steep-sloped mud bank 
with rubble and debris to the water's edge; the southern bank is a partially dilapidated creosoted wharf 
with pilings. There is some shallow littoral habitat along the southern bank about 2,000 feet bayward of 
the proposed construction site where the shoreline is undeveloped and is composed mainly of mud, with 
gravel, rubble, debris and some scattered sparse growths of weeds (i.e., the mud-flat area noted above). 
This area does support some foraging diving ducks such as pied-billed grebe {Podilymbus podiceps) and 
lesser scaup (Aythya affinis), both of which were observed during a site reconnaissance on February 6, 
2000. 

The generally degraded nature of the Islais Creek mouth offers little for aquatic species. A National 
Marine Fisheries Service survey conducted from 1984-1988 as part of the National Benthic Surveillance 
Project found only the white croaker (Genyonemus lineatus), also known locally as king-fish, in a bottom 
sample at the mouth of Islais Creek. Some persons were observed fishing at the project site on the 
February 6 site reconnaissance - when asked, they replied that they were fishing for, and catching, king- 
fish. Special status fishes (i.e.. Federally or State listed as endangered, threatened, or of concern) 
potentially inhabiting the project area include the tidewater goby {Eucyclogobius newberryi); winter and 
spring run Chinook salmon (Oncorhynchus tshawytscha); green sturgeon {Acipenser medirostris); 
longfin smelt (Spirinichus thalechthys); and steelhead (Onchorhychus mykiss). None of these species 
are, however, known to use Islais Creek, nor the Bay environs near the proposed project because of the 
degraded water quality and lack of spawning or foraging habitat. 

The most valuable aquatic habitat at the proposed bridge site is probably the partially dilapidated 
wharf/piling along the northern bank of Islais Creek that extends from the existing Third Street bridge for 
about 1,000 feet downstream (which includes the approximately 100 feet of bank at proposed bridge 
construction site). This habitat, which provides a "hard structure" for attachment, although probably 



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containing residual toxicity from creosote treatments prior to its installation, probably supports a diverse 
assemblage of invertebrates including mussels, crabs, isopods, tube worms, etc. This habitat also 
provides generally good substrate for Pacific herring (Clupea harengeus pallasii) spawning. The herring 
eggs are broadcast and adhesive - vegetation, pier pilings, riprap and other hard surfaces provide the 
preferred substrate for egg attachment. Pacific herring is of concern because it is one of the last 
remaining commercial fisheries in San Francisco Bay. It is the roe, or eggs, of the herring that are 
harvested from gravid females, rather than the herring flesh itself Peak spawning months are typically 
December through February. It is likely that Pacific herring spawn in the vicinity of the proposed bridge 
construction site. 

EXISTING WETLANDS 

Two areas provide small isolated wetland habitat in the Southern Waterfront area. One is Pier 98 
(developed into Heron's Head Park) and another is at Pier 94. Both sites are the result of subsided 
dredged and fill materials that were placed at these locations in the 1970s. These sites contain a total of 
about 8 acres of tidally influenced salt marsh habitat. 

Dominant plants at both sites are pickleweed (Salicomia subterminalis) in the middle tidal zone and 
saltgrass (Distichlis spicata) at the upper tidal zone. The Pier 94 wetland also contains gum-plant 
(Grindelia augustifolia) in the upper tidal zone, and cordgrass (Spartina sp.) in the lower tidal zone. 
These species are common salt marsh plants of the San Francisco Bay area. 

Heron's Head Park (Pier 98) consists of a developed trail winding along the approximately 2,000-foot 
long peninsula formed by disposal of fill and dredged materials in the 1970s. The northern shoreline of 
this peninsula is steep-sided, rip rap within the tidal zone, and has no native vegetation. About 3 acres of 
subtidal environment has formed in several small pockets of subsided materials along the unprotected 
southern shoreline of the peninsula. The subtidal zone is vegetated with pickleweed. The upper tidal 
zone around these pockets contains sparse growths of saltgrass bordered by iceplant. Much of the upland 
portion of this Park is non-native ornamental vegetation and wood chips bordering the trail. 

Heron's Head Park seems to be a particularly popular bird- watching area. Many of the trailside markers 
describe birds likely seen in along the Park's shoreline. It is likely that the bay waters adjacent to the 
southern edge of this peninsula are warmed by effluent from the PG&E Hunters Point power plant 
located adjacent to the Park. The warmer waters might increase productivity and attract fish and fish- 
eating birds to the area, creating an enhanced source of aquatic bird activity. 

Although there are numerous signs and string borders around native marsh vegetation at the Park, the 
marsh vegetation (i.e., saltgrass and pickleweed) is relatively sparse, likely due to the poor quality 
substrate materials. 

The Pier 94 wetland area occupies a rounded point of land along the southern mouth of Islais Creek. 
Tidally influenced salt marsh habitat has formed in two pockets of subsided fill materials along the 



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shoreline. These pockets total about 5 acres of mostly pickleweed. One of the pockets is slightly higher 
in elevation and contains mostly middle and upper tide zone vegetation (salt grass, pickleweed, and gum- 
plant). The other pocket is lower in elevation with no gum-plant, but with a few small bunches of 
cordgrass in the lower zone and surrounded by dense pickleweed. 

The Pier 94 wetland is bounded inland by a large area of dredged and fill material that has become 
upland vegetation with sparse growths of salt bush, non-native pampas grass, and ice plant. Portions of 
this upland area are currently being used as a construction materials handling and storage area. 

REGULATORY ENVIRONMENT 

Environmental regulations that require approvals for the proposed bridge construction include the 
following:44 

• Section 10 of the Rivers and Harbors Act, and Section 404 of the Clean Water Act require approval 
from the U.S. Army Corps of Engineers. This process would also invoke a consultation under 
Section 7 of the Endangered Species Act (Act). A preliminary phone conversation (Dick Butler, 
pers. comm.) with staff of the National Marine Fisheries Service (NMFS) in Santa Rosa indicated 
that there were no anadromous fishes of concern known to inhabit Islais Creek. This suggests that 
the consultation would be "informal" as defined by the Act and involve no significant permit 
conditions or mitigation measures which alter the analysis presented here 

• Water Quality Certification from the Regional Water Quality Control Board, in accordance with 
Section 401 of the Clean Water Act. 

• A Stream Alteration agreement from the California Department of Fish and Game. 

• Review and concurrence from the San Francisco Bay Conservation and Development Commission - 
BCDC has jurisdiction over all areas of San Francisco Bay subject to tidal action, and a shoreline 
band extending 100 feet inland. BCDC also has jurisdiction over salt ponds, managed wetlands, and 
certain other waterways, and is responsible for making a determination of consistency with the 
federal Coastal Zone Management Act. 



As noted in the Project Description, the Illinois Street Bridge would also need approval from the U.S. Coast Guard. 
Consideration of this approval would be based on navigational issues rather than environmental concerns. 



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In addition, design and construction of the bridge would be subject to approval of a bridge permit by the 
U.S. Coast Guard, which must determine the future navigational needs of Islais Creek before it issues a 
permit.'^^ 

IMPACTS 

SIGNIFICANCE CRITERIA 

To determine the level of significance of an identified impact, the criteria outlined in the CEQA 
Guidelines were used. CEQA (Section 15206) specifies that a project shall be deemed to be of statewide, 
regional, or area-wide significance if it would substantially affect sensitive wildlife habitats including but 
not limited to riparian lands, wetlands, bays, estuaries, marshes, and habitats for rare and endangered 
species as defined by Fish and Game Code Section 903. 

IMPACT ANALYSIS 
Illinois Street Bridge 

No significant adverse impacts of the project to biological resources have been identified, and no 
mitigation measures beyond those already included in the Waterfront Plan EIR are proposed. As noted 
below, avoiding activities during the December-February Pacific herring spawning season would reduce 
non-significant impacts to this species. 

Construction of the proposed Illinois Street Bridge across Islais Creek would cause both short-term 
construction impacts and longer-term changes in habitat that would have minor effects on the 
environment of Islais Creek in the immediate vicinity of the proposed bridge project. Construction 
impacts would include primarily water quality effects from disruption of bottom sediments when 
material is dredged for placement of bridge abutments or other in- water structures. Sediment suspension 
would cause some increases in turbidity and resettling of fine sediments that can smother and interfere 
with feeding or respiration of less mobile organisms in the project area. Sessile benthic'*^ invertebrates 
such as tube worms, clams, and mussels would be most susceptible to these effects. Fishes, crabs, and 
other mobile organisms would avoid the area during construction. If construction occurred during the 
Pacific herring spawning season (i.e., from December to February), any eggs attached to the 
wharf/pilings adjacent to the proposed construction site, or any newly hatched larvae, may be subject to 
smothering or other negative effects of the sediments released from dredging activities. 

In addition to the potential for physical effects from any dredging activities, resuspension of bottom 
sediments can release contaminants into the water column that are harmful to aquatic life. Of concern 



'^^ Because of the federal action and funding, environmental review of the bridge must also include completion of a document 
prepared by the Coast Guard pursuant to the National Environmental Policy Act (NEPA). 

Benthic organisms are those that live on the sea bottom. Sessile organisms do not generally move about, but rather are 
attached to hard surfaces or to the sea bottom. 



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would be highly organic materials that would increase the oxygen demand and possibly reduce oxygen 
levels in the adjacent waters sufficiently to harm some sessile organisms. Other contaminants found in 
the bottom sediments, likely from storm runoff of the nearby highly industrialized landscape, would 
include heavy metals, hydrocarbons, and oil and grease. If dredging would be required, the Corps of 
Engineers would require sediment analysis to determine the potential for contamination from any 
dredged sediments and specify disposal and dredging methods to accommodate the sediment character. 
However, effects would be less than significant because of the relatively small area that would be 
affected. 

Probably the most identifiable effects of dredging would be the effects on Pacific herring spawning. 
These could be mitigated by avoiding activities during the December-February Pacific herring spawning 
season when herring are present. If activities are proposed for December through February, a qualified 
biological monitor should survey the area to determine if spawning herring are present and, if so, the 
contractor would temporarily cease work (see Mitigation Measure F.la, p. 154). Effects on resident 
sessile organisms would not be considered significant, even locally, because of the limited and degraded 
nature of this resource. 

Longer term effects from bridge construction would include any displacement of existing soft bottom or 
other natural habitat by bridge abutments and/or other structures placed in, or along the water edge. This 
would remove habitat for some burrowing invertebrates such as clams and tubeworms, which are, in 
turn, forage for resident fishes such as the white croaker. This habitat would be replaced with concrete 
and thus offer "hard surface" habitat for attached organisms such as mussels and Pacific herring eggs. If 
the wharf/pier habitat along the southern bank is removed and replaced with another material, this would 
affect the potential of that particular site to support the assemblage of "hard surface" organisms noted 
above. This might include displacing some Pacific herring spawning habitat. It is likely, however, that 
the concrete that would replace the creosoted wooden wharf/pier habitat would offer some "hard 
structure" habitat for the same kinds of organisms - and without the toxicity of creosote. Whether the 
habitat is improved or reduced in value, the change would be very minor because of the generally 
degraded quality of the existing habitat and the small quantity of change in relation to the overall habitat 
of this kind in the area (i.e., only about 100 feet of wharf/pier habitat would be affected by bridge 
construction). 

The mud/rubble northern bank of Islais Creek at the proposed bridge construction would also be replaced 
with concrete abutment. This change would eliminate a very small area of shallow littoral habitat. This 
habitat is, however, of little value to the aquatic or riparian biota in the project vicinity. The bank is 
steep and the zone of shallow water is very narrow and contains no aquatic or wetland vegetation. 
Bridge construction would limit very little foraging opportunities for aquatic birds that may use this area 
such as scaup and grebe. The new bridge and concrete abutment habitat may increase use of the area by 
rats, starlings, and other urban species better adapted and tolerant of industrialized waterfront habitat. 



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m. ENVIRONMENTAL SETTING AND IMPACTS 



F. BIOLOGICAL RESOURCES - IMPACTS 



Other Impacts 

There are wetlands located in the Southern Waterfront but outside the vicinity of the proposed Illinois 
Street bridge. The Waterfront Plan EIR notes (p. 556) that wetlands at Pier 98 (now known as Heron's 
Head Park) and at Pier 94 (Seawall Lot 352) could be adversely affected by contaminated runoff and by 
public access. Concerning the former, please see the discussion of stormwater runoff (p. 1 1 1) in 
Section III.D, Hydrology, where it is concluded that effects would be less than significant. Concerning 
the latter. Heron's Head Park has been constructed with numerous signs warning visitors to stay out of 
wildlife habitat areas, while the Pier 94 wetlands would continue to be located in areas surrounded by 
industrial uses and therefore would not be subject to public access. Furthermore, the Waterfront Plan 
calls for "reserv[ing] or improv[ing] areas which will provide opportunities for the protection of wildlife 
habitat and for passive and active recreational areas" (p. 146). Included in the Plan is the following 
concerning the Pier 94 wetlands: 

As a result of [a failure of fill adjacent to Pier 94 in the 1970s], adjacent fill material subsided, 
allowing tidal inundation and subsequent emergence of wetlands. If development of this property 
for interim or long-term uses causes filling of the wetlands, appropriate mitigation measures will 
be required. 

The project includes British Pacific Aggregates' proposed aggregate import terminal on the paved area of 
Pier 94, south of the existing wetlands, and the Port's proposed dredge material storage facility, upland 
from the wetlands. Neither of these components would encroach into the existing wetlands, and 
therefore no significant effect would occur, and no mitigation is required. 



G. GROWTH INDUCEMENT 

In general, a project would be considered growth-inducing if its implementation would result in 
substantial population increases and/or new development that might not occur if the project were not 
approved and implemented. Both the Industry Group project components and the proposed Illinois 
Street Intermodal Bridge would primarily be linked to maritime and industrial activities along San 
Francisco's Southern Waterfront, which represent a relatively small and - in percentage terms - 
declining portion of the City's economy. 

The six project components proposed by the Industry Group include four that would relocate from 
elsewhere in San Francisco. Two Industry Group members represent the City's two largest concrete 
producers, both of which are required to relocate from long-time locations due to changing land use 
patterns with the Mission Bay project area. The other two relocations - one a tour bus and commuter bus 
operator and the other, a construction materials recycler - would relocate due to expiration of leases at 
existing locations. The other Industry Group components would supply raw materials and/or finished 
products related to concrete and asphalt production.. In short, with the exception of Coach USA, the bus 
operator, all of the Industry Group project components are proposed to respond to demand for 
construction materials as a result of both private- and public-sector development projects. While a 



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G. GROWTH INDUCEMENT 



shortage of these materials could delay and/or increase the cost of such development projects, an increase 
in the potential supply of construction materials is unlikely, in itself, to result in any change in 
development activity in San Francisco or the Bay Area. Thus, the construction-related Industry Group 
project components are not likely to have any growth-inducing effects. 

The Coach USA tour/commute bus storage and maintenance facility would be a relocation of an existing 
operation that provides services to the existing tourism industry and to public transit agencies, which 
whom the firm contracts to provide coramute bus service. Because it would be a continuation of an 
existing use, and because there are several other tour bus operators in San Francisco and the region, this 
project component, too, would not be expected to result in any growth-inducing impacts. 

The Illinois Street Intermodal Bridge proposed by the Port of San Francisco would also serve existing 
facilities, namely the Port's container terminals as Pier 80 and Piers 94-96. Although the bridge would 
improve rail and truck transportation to and between these facilities, the bridge, in itself, is unlikely to 
result in any perceptible change in cargo shipping activity at the Port of San Francisco. In fact, much 
like the relocation of the existing concrete plants, the bridge would accommodate land use changes in the 
Mission Bay area, as it would provide a rail route to the North Container Terminal at Pier 80 to replace 
the existing rail route that travels north from the county line to 16th Street, within the Mission Bay area, 
and then south to Pier 80 along Illinois Street. Therefore, the Illinois Street bridge would not have any 
meaningful growth-inducing impacts. 



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CHAPTER IV 



MITIGATION MEASURES PROPOSED TO MINIMIZE THE 
POTENTIAL ADVERSE IMPACTS OF THE PROJECT 

In the course of project planning and design, measures have been identified that would reduce or 
eliminate potential significant environmental impacts of the proposed project. Some of these measures 
have been voluntarily adopted by the Port and/or private project proponents and thus are to be 
implemented as part of the project. Other measures are identified as a result of this analysis but have not 
as yet been incorporated into the project. Each mitigation measure and its status are discussed below. 

There are several items required by law that would serve to mitigate potential significant impacts; they 
are summarized here for informational purposes. These measures include: no use of mirrored glass on 
the building to reduce glare, as per City Planning Commission Resolution 9212; limitation of 
construction-related noise levels, pursuant to the San Francisco Noise Ordinance (Article 29 of the 
San Francisco Police Code, 1972); observance of regulations promulgated by the Regional Water Quality 
Control Board and the Bay Area Air Quality Management District; compliance with Chapter 36 of the 
San Francisco Building Code, Work Practices for Exterior Lead-Based Paint; and observance of State 
and federal OSHA safety requirements related to handling and disposal of other hazardous materials, 
such as asbestos. 

Measures that are not required by legislation but would serve to mitigate potentially significant 
environmental impacts appear below. Also, where legal requirements exist but provide little specificity 
with regard to likely compliance actions, such as components of a Stormwater Pollution Prevention Plan, 
certain specific elements of these requirements that would be required to ensure that no significant 
impact would occur are identified as mitigation. 

As described in the Introduction, this is a Supplemental EIR. Accordingly, this chapter indicates the 
disposition of mitigation measures that were identified in the 1997 Waterfront Land Use Plan (WLUP) 
FEIR and approved by the Port Commission with adoption of the Waterfront Plan in June 1997. Some of 
those measures remain applicable to the project as currently proposed and have been incorporated here, 
while others have been modified in this SEIR. Some measures do not apply to the project analyzed in 
this SEIR, principally because they were identified in reference to other components of the Waterfront 
Plan analyzed in 1997, such as areas of the waterfront other than the Southern Waterfront; they are so 
noted. Where a measure is not noted as being from the 1997 FEIR, it is newly identified in this SEIR. 

A. LAND USE 

No mitigation measures are required for the current project. 



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B. TRANSPORTATION 



B. TRANSPORTATION 



MEASURE IDENTIFffiD IN THIS SEIR 

B.l To mitigate 2015 conditions, monitor traffic level of service (LOS) conditions at the intersections 
listed below in Table 23. At such time as warranted by traffic conditions (i.e., a degradation of the 
p.m. peak-hour service level to an unacceptable LOS E or F), institute the identified improvements 
or implement another measure determined at that time to be adequate to mitigate the degradation 
in level of service. 

TABLE 23 

MITIGATION MEASURES FOR INTERSECTION LEVELS OF SERVICE 



2015 Level of Service 
A.M. Peak Hr. P.M. Peak Hr. 

Project LOSw/ Project LOS w/ 
Intersection Mitigation Measure LOS Mitig. LOS Mitig. 



Third / 25th 
Streets t 



Illinois / 25th 

Streets U 
Pennsylvania / 

1-280 SB 

On-Ramp tt 
Pennsylvania / 

Cesar Chavez 

Streets 
Third / Cesar 

Chavez Streets 



Illinois / Cesar 
Chavez Streets 



Amador Street / 
Cargo Way 



• Restripe the east- and westbound approaches to 
provide left-turn lanes. 

• Revise signal timing to provide protected east- and 
westbound left-turn phases. 

• Install traffic signal. 

• Install traffic signal. 



• Reconstruct the roadway to provide an exclusive 
northbound right-turn lane ("free" right-turn). 

• Add a second northbound left-turn lane and an 
additional lane in each direction to the western 
approach on Cesar Chavez Street. (This would 
require the acquisition of additional right-of-way on 
Third Street at the southeast comer of the intersection, 
where there is an existing building.) 

• Install traffic signal. 

• Restripe the northbound and southbound approaches 
to provide left-turn lanes and shared right-through 
lanes. 

• Restripe the eastbound and westbound approaches to 
provide a shared left-through lane and a shared 
through-right lane. 

• Install traffic signal. 

• Restripe the southbound Amador Way approach to 
provide a left-turn lane, a shared left-through lane, and 
a right-turn lane. 



D 

B(C) 
B(C) 



A 
B 

D 



t - Mitigation required only in p.m. peak hour. 

+ - LOS and delay reported for overall intersection; LOS in parentheses is for critical movement, when worse than 
overall LOS. 

SOURCE: Wilbur Smith Associates 



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IV. MITIGATION MEASURES 



B. TRANSPORTATION 



B.2 At such time as specific mixed-use or other non-industrial projects generating more than 100 daily 
vehicle trips are approved and occupied at the Pier 70 Mixed-Use Opportunity Area and the 
Pier 90-94 backlands, the Port shall develop a Transportation Systems Management (TSM) Plan, 
and potentially a Transportation Management Agency (TMA) that would consist of Port staff. Port 
tenants, property owners, and project occupants. The goals of the TSM Plan and the TMA shall be 
to reduce, to the maximum feasible extent, the use of single-occupancy automobile traffic and 
encourage other forms of travel to and from work, including transit, carpooling and ridesharing, 
bicycle, walking, and other means. 

B.3 The Illinois Street bridge that is proposed by the Port would improve operating conditions at Third 
Street and Cargo Way to an acceptable level of service (LOS C in the a.m. peak hour and LOS D in 
the p.m. peak hour), compared to conditions without the proposed bridge. 

MEASURES FROM THE 1997 WATERFRONT PLAN FEIR, AS APPROVED BY 
THE PORT COMMISSION, JUNE 1997 (Included in the Project) 

B.4 The Port shall comply with requests from the Major Environmental Analysis section of the 

Planning Department to analyze intersection levels of service for existing and future conditions at 
intersections that may reasonably be expected to be affected by each future development project, 
and shall identify and implement appropriate mitigation measures. 

Any such transportation analysis would need to be coordinated with monitoring of the Congestion 
Management Program network, conducted biennially by the San Francisco County Transportation 
Authority as the designated Congestion Management Agency for San Francisco County. Within 
the WLUP Project Area, The Embarcadero, King, Third and Fourth Streets are all included on the 
Congestion Management Program network. A number of intersecting streets (North Point, Bay, 
Broadway, Washington, Clay, Cesar Chavez, and Evans west of Third) are also included on the 
CMP network. The Authority would conduct monitoring activities along these facilities, but only 
in the context of determining changes in Level of Service for arterial segments (not for individual 
intersections). Degradation of the Level of Service for one or more individual intersections within 
an arterial segment, to Level of Service "F" or to below some other designation deemed to be 
acceptable, could also degrade the segment Level of Service. The degree of impact to the segment 
may not be sufficient for the Transportation Authority to identify a "deficiency" under the CMP 
process (Level of Service "F" for the entire segment), even though the Port or City could impose 
mitigation requirements for developers of projects that would have a significant impact on 
individual intersections. Based on the transportation analysis for this EIR, cumulative 
development along the Waterfront might cause degradation of a particular segment of the CMP 
network to fall to "F," thereby triggering a finding of deficiency requiring formulation of a 
Deficiency Plan, and implementation of that Plan under the CMP processes identified by the 
Transportation Authority. The Authority could, in this circumstance, identify the Port as the lead 
agency for development of the Deficiency Plan and for implementation of any corrective 
measures, and the Port could require sponsors of specific development projects that contribute to 
cumulative congestion to participate in improvement and mitigation measures. ( 7997 FEIR 
Measure DA) 

B.5 To help induce shifts from vehicles to transit and thereby partially mitigate local intersection 
impacts and regional highway impacts, the Port could require and/or institute Transportation 
Demand Management Programs among developers of major trip generators, as a condition of lease 



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IV. MITIGATION MEASURES 

B. TRANSPORTATION 

approval. This would apply in particular to future Port development at Pier 70 and the Pier 90-94 
backlands. 

Such programs typically target primarily commute trips, with various educational, assistance and 
incentives measures to encourage carpooling and vanpooling, and transit use. These measures may 
be accompanied by such "disincentives" to low-occupant private vehicle use as restricting the 
amounts and/or location of parking made available to employees, and charging higher fees for all- 
day parking. Also typical are measures designed to shift time of commute travel to the "shoulders" 
of the peak, and/or to encourage less trip making through alternative work schedules and 
telecommuting. The effectiveness of these programs is variable, but they are most appropriate and 
effective when there are substantial constraints to vehicular travel, circulation and storage coupled 
with suitable options such as excellent transit accessibility. San Francisco in general, and its 
downtown and portions of the waterfront in particular, exhibit this combination of factors. 

The Port could also design and implement similar programs which would target non-commute 
travel. An example of the type of measure which might be included is the issuance of discount 
admission to some uses, or reductions in the price of services and/or merchandise, upon 
presentation of a valid transit transfer or other proof of transit use payment. Additionally, a free 
shuttle along The Embarcadero could be a part of this type of program, and would help to alleviate 
local auto congestion. ( 1997 FEIR Measure D-7) 

C. AIR QUALITY 

Measure B.3, above, would reduce but not eliminate the project's contribution to potentially significant 
air quality impacts. The mitigation measures in this section would further reduce but not eliminate the 
project's contribution to potentially significant air quality impacts. 

MEASURES INCLUDED IN THE PROJECT 

C.l Each of the Industry Group construction aggregate industry project components, which would 
represent "stationary sources" of particulate emissions, shall include "best available control 
technology" (BACT) to control emissions, consistent with current regulations. For aggregate-handling 
operations (Bode Gravel, Mission Valley Rock, RMC Pacific, British Pacific Aggregates), this 
includes maintaining a moisture content in the aggregate that is high enough to eliminate PM-10 
"fugitive" emissions (wind-blown dust that could otherwise escape into the surrounding air). A water 
spray system shall be installed at each aggregate-handling facility, including Bode Gravel, Mission 
Valley Rock, RMC Pacific, and British Pacific Aggregates. Fine aggregate material (sand) shall be 
maintained with a moisture content of approximately 5 percent, because such material with a moisture 
content of 4.5 percent or more produces virtually no fugitive emissions. Coarse aggregate (gravel) 
shall be kept damp on the surface, which would also effectively eliminate fugitive dust. Aggregate 
shall be stored in bunkers at ready-mix and asphalt plants, rather than open piles, with water spray 
(including the use of surfactants, as necessary, to bind the water and dust to the aggregate) applied to 
maintain adequate moisture content to control emissions at both production and shipping/storage 
operations. ISG Resources, which would handle fly ash, a finer, more powdery material than 
aggregate, shall install BACT dust collection equipment to accommodate truck and rail transport and 
shall use pneumatic equipment to control dust emissions during the transfer of fly ash. 



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C. AIR QUALITY 

C.2 The asphalt plant proposed by Mission Valley Rock (and potentially the British Pacific asphalt 

plant) shall include controls on the drum mixer where the asphalt cement and aggregate are mixed. 
Drum mixer(s) shall be fired with natural gas, consistent with Best Available Control Technology 
(BACT) recommendations, and particulate emissions from the aggregate drying and mixing 
process shall be controlled with a fabric filter, also consistent with BACT. Such filters can achieve 
control efficiency of greater than 99 percent. 

C.3 Consistent with the City's Clean Air Program (established by Ordinance 258-99, adopted 

October 15, 1999), it is City policy to "foster, promote, and encourage the use of low emission 
[alternative fuel vehicles] and [zero emission vehicles] by developing infrastructures to support the 
use of these vehicles." Under the ordinance, the City is to (1) assess the need for a network of 
natural gas fueling stations accessible to the public; (2) site and develop at least five such facilities, 
by public and/or private entities; (3) install 50 publicly accessible electric vehicle charging stations 
in City garages, lots, or other sites; (4) develop a plan for additional charging stations and related 
infrastructure; (5) buy and lease ultra-low and zero emission vehicles for City department use; (6) 
identify and convert diesel bus lines to electric service; (7) develop a plan to phase out older diesel 
buses; (8) develop a plan and incentives to encourage larger private vehicle fleets to convert their 
fleets to very low or zero emission vehicles; and (9) develop a car sharing program in high density 
neighborhoods. 

Consistent with the City's Clean Air Program, the Port shall require that all tenants make a good 
faith effort to engage in operational practices sensitive to the environment and the neighboring 
community. In furtherance of this, the Port shall require that tenants operating a fleet of vehicles 
investigate the potential for use of low- or zero emission vehicles and implement measures to 
reduce vehicle emissions to the maximum feasible extent. Options may include, but not 
necessarily be limited to, the use of low-emission diesel fuel (including low-sulfur diesel); the use 
of catalytic particulate traps for diesel-powered engines that are currently under study by the 
California Air Resources Board; the use of other emerging technologies to reduce diesel particulate 
emissions; and use of electric vehicles. The Port shall also require that tenants operating diesel- 
powered stationary equipment investigate similar options. Tenants shall investigate retrofitting 
existing engines and purchase of new engines. The Port shall further require that tenants who 
work with independent trucking contractors encourage those contractors to make similar efforts, 
including, if reasonably feasible, providing such truckers with economic incentives to retrofit 
equipment or take other measures as may be necessary to use low-emission fuels. As an economic 
incentive to minimize diesel emissions from Port property, the Port shall contribute towards the 
incremental costs incurred by its tenants for Port-approved equipment and improvements in 
furtherance of this measure. Finally, the Port shall establish a schedule by which tenants described 
above shall report to the Port on progress in investigating reduced-emission engines. 

C.4 At such time as specific mixed-use or other non-industrial projects generating more than 100 daily 
vehicle trips are approved and occupied at the Pier 70 Mixed-Use Opportunity Area and the 
Pier 90-94 backlands, the Port shall develop a Transportation Systems Management (TSM) Plan, 
and potentially a Transportation Management Agency (TMA) that would consist of Port staff. Port 
tenants, property owners, and project occupants. The goals of the TSM Plan and the TMA shall be 
to reduce, to the maximum feasible extent, the use of single-occupancy automobile traffic and 
encourage other forms of travel to and from work, including transit, carpooling and ridesharing, 
bicycle, walking, and other means. 



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C.4A To regulate the production of concrete or asphalt material consistent with the volumes analyzed in 
the Southern Waterfront SEIR, any lease for concrete or asphalt batching operations on Port 
property shall include a provision setting forth the maximum production volume allowed under the 
lease, such that the cumulative total of production volumes of such batching operation leases shall 
not exceed the volumes assumed and analyzed in the SEIR. 

To monitor production volumes that may occur on Port property, the Port shall require as a 
condition of each lease that each tenant provide annually an audited account of the concrete and/or 
asphalt production volumes provided by each concrete or asphalt production business. The Port 
shall incorporate this information in an annual report to the Port Commission. 

Should any existing tenants propose to increase production above the amounts stipulated in the 
lease, such change would require an amendment to the lease, and would be subject to further 
environmental review by the San Francisco Planning Department's Major Environmental 
Assessment (MEA) division. In determining whether further environmental impact analysis will 
be required, MEA will consider the production levels cited in the Port's report and any emission- 
reducing improvements that may have been incorporated into the on-site operations (stationary 
sources), and trucks and other vehicles associated with the operations (mobile sources). 



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REVISED MEASURE FROM THE 1997 WATERFRONT PLAN FEIR, AS 
APPROVED BY THE PORT COMMISSION, JUNE 1997 (Included in the Project) 

C.5 The Port shall require that project sponsors direct construction contractors to implement a dust 
abatement program to reduce the contribution of project construction to local PM-10 
concentrations. Elements of this program, which is currently applied to all Port tenants, include 
the following: 

• Water internal roadways and unpaved construction areas just prior to the moming and 
evening peak traffic periods (to limit the potential for major roadway traffic to entrain dust), 
limit speeds to 10 mph, and sweep paved internal roads after the evening peak period. 

• In addition, water active sites (e.g., where demolition, excavation or other earth work is 
underway) at least twice per day. Increase the frequency of watering when wind speeds 
exceed 15 miles per hour. Suspend all excavating and grading operation when instantaneous 
gusts exceed 25 miles per hour. 

• Replace ground cover in disturbed areas as quickly as possible. 

• Enclose, cover, water twice daily, or apply soil binders to exposed stockpiles of sand, gravel, 
and dirt. 

• Install gravel at construction equipment entrances to unpaved areas to prevent tracking of 
dirt and mud onto streets. 

• Sweep paved access roads, parking areas, and construction staging areas, at the end of day 
(with water sweepers), and sweep adjacent City streets if any visible soil material is carried 
over to these streets. 

• Cover all trucks hauling dirt, sand, soil, or other loose materials. Maintain at least six inches 
of freeboard between the top of the load and the top of the trailer. 

• Sweep up dirt or debris spilled onto paved surfaces immediately to reduce resuspension of 
particulate matter through vehicle movement over these surfaces. 

• Designate a person or persons to oversee the implementation of a comprehensive dust 
control program and to increase watering, as necessary. 

• Maintain and operate construction equipment so as to minimize particulates from exhaust 
emissions. During construction, require contractors to operate trucks and equipment only 
when necessary. Equipment should be kept in good condition and well-tuned, to minimize 
exhaust emissions. 

Ordinance 175-91, passed by the Board of Supervisors on May 6, 1991, requires that non-potable 
water be used for dust control activities. Therefore, the project sponsor shall require that the 
contractor(s) obtain reclaimed water from the Clean Water Program for this purpose. 



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This mitigation measure also would reduce demolition-related impacts regarding lead paint 
chips/lead dust. The project sponsor shall also be required to comply with Chapter 36 of the 
San Francisco Building Code, Work Practices for Exterior Lead-Based Paint, enforced by the 
San Francisco Department of Building Inspection. 

MEASURE IDENTIFIED IN THIS SEIR 

C. 6 Consistent with the construction-period dust abatement program described in Mitigation Measure 

C.5, the Port shall require that Industry Group components and other aggregate-related tenants 
employ dust abatement procedures including, but not necessarily limited to, the following: 

• installation and operation of truck wheel-washing systems at the plant exits; 

• daily street sweeping on streets surrounding aggregate-related facilities; and 

• clearly posting on the exterior wall or fence of such facilities a company telephone number 
for citizens to call with dust, noise, or other operational complaints, and designation of a Port 
staff contact for same. 

No other feasible mitigation measures have been identified that would reduce the project's total regional 
emissions to a level below Bay Area Air Quality Management District thresholds, or eliminate the 
project's contribution to potentially significant cumulative impacts from all existing (unquantified) and 
future (unknown) emissions sources. 

D. HYDROLOGY 

MEASURES INCLUDED AS PART OF THE PROJECT 

D.l For construction sites of less than five acres of disturbed area, the contractors shall be required to 
prepare and implement a Storm Water Pollution Prevention Plan (SWPPP) similar to that required 
under the statewide General Permit for Storm Water Discharges Associated with Construction 
Activity. The SWPPP would include site-specific information to identify and evaluate sources of 
pollutants associated with industrial activities and to identify and implement site-specific best 
management practices to reduce or prevent pollutants associated with industrial activities in 
stormwater discharges. Best management practices may be non-structural (e.g., activity schedules, 
maintenance procedures, prohibitions of practices) or structural (e.g., treatment measures, runoff 
controls, overhead coverage). Elements of the SWPPP shall include the following: 

• measures for erosion and sediment controls 

• methods for construction waste handling and disposal, and 

• post-construction erosion and sediment control requirements. 



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rv. MITIGATION MEASURES 



D. HYDROLOGY 



D.2 To minimize the potential for water quality degradation from stormwater runoff, the Port shall 
require that all tenants and developers, including interim lessees such as the Industry Group 
members, implement source control Best Management Practices consistent with those identified in 
the Industrial / Commercial Storm Water Best Management Practices Handbook (Stormwater 
Quality Task Force, 1993). Measures shall include, but are not limited to, the following (some of 
which are proposed as part of one or more Industry Group components): 

• prohibiting discharge of process water to storm drains or otherwise directly to the Bay or Islais Creek; 

• separating stormwater from process water, such as concrete truck washout water and truck 
wash water, through the use of berms and other features, and ensuring that treated stormwater 
to be discharged to the Bay meets applicable permit and regulatory standards, including pH 
(acidity or akalinity); 

• for Industry Group components that would use water in dust control, creation of settling basins 
or similar features that would allow sediment to be removed from water prior to reuse and/or 
discharge; 

• daily street sweeping of surrounding streets and, for facilities that operate on unpaved surfaces, 
installation and operation of truck wheel-washing systems at aggregate-related plants; 

• employing appropriate containment measures for fuel, asphalt cement, and other hazardous 
materials stored on-site, to capture potential spills (including at on-site fueling areas); 

• installing and maintaining grease and sediment traps at vehicle maintenance and washing 
areas to prevent contaminated runoff from entering the storm drains or Bay; 



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IV. MITIGATION MEASURES 

D. HYDROLOGY 

• installation of sediment containment systems around outdoor aggregate storage facilities to 
limit sediment entering stormwater runoff, and covering such storage areas if feasible to 
limit stormwater infiltration; 

• creation of a designated wash-out area for concrete trucks to prevent concrete slurry from 
reaching the Bay; and 

• cover any open conveyors in use over the Bay (i.e., between piers and ships and barges) to 
minimize the potential for direct sediment spill to the Bay. 

REVISED MEASURES FROM THE 1997 WATERFRONT PLAN FEIR, AS 
APPROVED BY THE PORT COMMISSION, JUNE 1997 (Included in the Project) 

D.3 As part of permit and lease requirements for future Port development projects, runoff from 

stormwater at new or re-developed facilities located outside of the City's combined sewer system 
shall be, at a minimum, subject to appropriate treatment such as on-site oil/water separators and/or 
sediment traps, depending on the nature of the pollutants that may be in the runoff, so that 
stormwater runoff is treated prior to discharge and that there is no direct, untreated discharge to the 
Bay or Islais Creek. Stormwater runoff from future Port development sites shall not be directed to 
the City's combined system, as originally contemplated in the Waterfront Plan EIR, and the 
volume of stormwater flows from the project area to the City's combined sewer system shall 
remain the same as at present, unless the increased flow to the combined system would result in no 
additional volume of combined sewer overflows. 

D.4 Sponsors of individual project components, including members of the Industry Group, shall be 

required to implement appropriate Best Management Practices for stormwater pollution prevention 
throughout the life of each lease and shall be required to monitor stormwater quality in accordance 
with the requirement of the statewide General Permit for Discharge of Industrial Stormwater. 

D. 5 Sponsors of individual project components, including members of the Industry Group, shall 

conduct water quality monitoring during construction of facilities on or adjacent to the Bay to 
minimize effects of construction activities on water quality. In order to minimize potential for 
spills, construction materials or debris to enter the Bay and affect water quality, site specific 
construction methods and precautions, such as limiting activities on days of strong winds, could be 
included in the contractor's construction specifications to minimize effects on water quality. 
Demolition of structures with lead-based paint should include physical precautions to ensure that 
paint dust and chips do not enter the Bay. 

E. HAZARDS 

MEASURES INCLUDED AS PART OF THE PROJECT 

E.l Accidental Release of Hazardous Materials or Petroleum Products 

In accordance with the Hazardous Materials Ordinance, the sponsor of each Industry Group or Port 
project component shall ensure that a Hazardous Materials Business Plan is prepared for each of 
the project components involving the use of petroleum products or hazardous materials. The plan 
would specify methods for handling and storage of these including containment, site layouts, and 
emergency response and notification procedures for a spill or release. 



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rV. MITIGATION MEASURES 

E. HAZARDS 

The project sponsor(s) shall ensure that a Spill Control and Countermeasure Plan is prepared for 
any project involving the aboveground storage of petroleum products. The plan would include 
requirements for appropriate spill containment or equipment to divert spills from sensitive areas, a 
discussion of facility-specific requirements for the storage system, inspections and a record 
keeping system, security for the system, and personnel training. The project sponsor(s) would also 
comply with the state requirement that above-ground storage tanks subject to federal regulations 
are registered with the Regional Water Quality Control Board. 

£.2 Hazardous Materials in Soil 

E.2a Because the Bode Gravel and Mission Valley Rock projects would be constructed bayward of the 
historic high tide line and would involve the excavation of at least 50 cubic yards of soil, the 
sponsors of those components shall ensure that the contractors comply with the requirements of 
Article 22A, "Analyzing the Soil for Hazardous Wastes." In accordance with the approved site 
mitigation report for this project component, the site would be capped with an asphalt or concrete 
slab and structures. Upon completion of capping, a certification report would be prepared to 
document construction activities and a maintenance report would be prepared specifying 
procedures to be followed to control exposure to the subsurface soil following construction of the 
proposed project. These reports would be submitted to the San Francisco Department of Public 
Health for review and approval to ensure regulatory compliance. 

For any other Industry Group or Port-sponsored project components for which Article 22A would 
apply (including the Illinois Street bridge, if applicable), a site history report, soil investigation, 
and soil analysis report would be completed to identify potential hazardous materials at this site. 

If indicated by the results of the soil investigation, the project sponsor would ensure that the 
contractors for each project prepare a Site Mitigation Report in compliance with Article 22A if 
warranted by the levels of hazardous materials identified in the soil. The plan would include 
measures for the handling of soil produced during excavation, to control dust and runoff during 
construction, and to characterize soil for off-site disposal purposes. Upon completion of 
construction, the project sponsor would ensure that the construction contractors prepare a 
certification report certifying that either (1) no hazardous wastes present in the soil present an 
unacceptable risk and that no mitigations are required; or (2) all mitigation measures specified in 
the site mitigation report have been completed and that completion of the mitigation measures has 
been verified through follow up sampling and analysis, if required. All reports would be submitted 
to the San Francisco Department of Public Health (DPH) for review and approval to ensure 
regulatory compliance. 

The project sponsor shall prepare and submit to DPH a site-specific Safety and Health Plan (SHP) 
that would address worker safety concerns resulting from potential contaminants on the site. The 
SHP would include provisions for responding to unknown hazardous materials site conditions that 
could be encountered during construction. 

If the soil investigation demonstrates that hazardous wastes present in the soil could be at levels 
that pose an unacceptable health risk, the project sponsor would ensure that appropriate site 
investigations and risk evaluations are performed to evaluate potential human health risks related 
to any hazardous substances left in the soil or groundwater after completion of construction. The 
investigations, risk evaluations, and any required remedial actions would be implemented under 
the oversight of the appropriate regulatory agency(ies) to ensure compliance with applicable laws 
and that the public health and safety are protected. 



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E. HAZARDS 

E.2b For all projects where subsurface contamination is identified, the project sponsor would ensure that 
from the time that ground surfaces are exposed until the time that all remedial activities have been 
completed, a fence is erected around the area where chemicals have been identified in the soil and 
site access is restricted to necessary personnel. Waming signs prohibiting access by the general 
public onto the project site would be posted at all construction access points. Access would be 
limited to authorized personnel only. 

Dust-control measures applicable for air quality impacts would also minimize the potential public 
health impact associated with dust emissions and air quality pollutants. (See also Air Quality 
Mitigation Measures.) 

MEASURE PROPOSED BY THE PORT AS PART OF THE PROJECT 
E.3 Soil Disposal 

The Port shall contract for or require that Port tenant(s) contract for disposal of any portion of the 
soil pile on the Bode and Mission Valley Rock sites at Pier 92 that cannot be reused for 
construction projects in accordance with applicable waste disposal regulations. Such reuse would 
also require approval of the San Francisco Department of Public Health. 

REVISED MEASURE FROM THE 1997 WATERFRONT PLAN FEIR, AS 
APPROVED BY THE PORT COMMISSION, JUNE 1997 (Included in the Project) 

E.4 Hazardous Building Materials 

The project sponsor for each Industry Group component and each future Port development 
component involving demolition or renovation of existing facilities shall ensure that hazardous 
building material survey(s) for asbestos, PCB -containing equipment (including transformers, 
elevator equipment, and other applicable equipment), hydraulic oils, fluorescent lights, and lead- 
based paint is conducted prior to the start of demolition or renovation, for each such project 
component. The survey(s) would be completed by a Registered Environmental Assessor or a 
registered engineer prior to construction or demolition activities. If any friable asbestos-containing 
materials or lead-containing materials are identified, adequate abatement practices, such as 
containment and/or removal, would be implemented prior to demolition or renovation. Detailed 
requirements for the assessment, abatement, and disposal of hazardous building materials are presented 
in Appendix F. Any PCB-containing equipment or fluorescent lights containing mercury vapors 
would also be removed and disposed of properly. 

Any hazardous materials discovered through building survey(s) would be abated according to 
federal, state, and local laws and regulations. In particular, the project sponsors will be required to 
comply BAAQMD requirements for the removal of friable and non-friable asbestos containing 
materials as well as other requirements of Cal/OSHA, BAAQMD and the Contractors Licensing 
Board for abatement of asbestos prior to demolition. 



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F. BIOLOGICAL RESOURCES 



REVISED MEASURES FROM THE 1997 WATERFRONT PLAN FEIR, AS 
APPROVED BY THE PORT COMMISSION, JUNE 1997 (Included in the Project) 

F.la The Port could limit dredging operations and other construction activity in connection with the 

Illinois Street Bridge to between March 1 and November 30 to eliminate any potentially significant 
impacts of dredging or pier repair/replacement on the Pacific herring fishery. The Port would 
specify in construction contracts that, in exceptional cases where dredging operations or bridge 
construction must conflict with the herring season, the following conditions must be fulfilled: 

• A professional fisheries biologist or other individual sufficiently competent to identify 

herring spawning activity would monitor the project site daily at any time when dredging or 
other in-water construction activity were taking place. 



• In the event that the on-site monitor detects herring spawning at, or within 200 meters of 
dredging or other in-water construction activity, the monitor would immediately notify the 
Environmental Review Officer and the project construction manager, who would halt the 
dredging or other construction activity for a minimum of 14 days, or until the monitor 
determines that the hatch has been completed and larval herring have left the site. The 
dredging or other construction activity may resume thereafter. 



F.lb Project sponsors of Industry Group project components would similarly limit dredging operations 
and pier repair/replacement to between March 1 and November 30 to eliminate any potentially 
significant impacts of dredging or pier repair/replacement on the Pacific herring fishery. In 
exceptional cases where dredging operations or major pier repair/replacement operations (beyond 
routine maintenance) must conflict with the herring season, the project sponsor(s) would consult 
with the permitting agencies, including but not necessarily limited to the U.S. Army Corps of 
Engineers, Bay Conservation and Development Commission, State Department of Fish and Game, 
and Regional Water Quality Control Board. The sponsor(s) would comply with specific 
monitoring requirements established by these and other agencies to avoid impacts on the herring 
fishery. 

F.2 Prior to demolition or renovation of any abandoned building between August 15 and October 15, 
or between February 1 and May 1, project sponsor(s) would ensure that survey(s) are conducted 
during the same period by a qualified bat biologist. If no Townsend's western big-eared bats are 
found during the survey(s), no additional mitigation is required. 

If Townsend's western big-eared bat, a California Species of Special Concern, is found during an 
August - October survey, appropriate exclusion devices approved by CDFG & USFWS should be 
installed by a qualified bat biologist. Once the bats have been excluded, demolition may occur. 

If Townsend's western big-eared bats are found during a February - May survey, demolition 
should not take place until the end of the nursery season in August. Exclusion devices should be 
placed by a qualified bat biologist in accordance with CDFG and USFWS. 



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G. GEOLOGY, SOILS, AND SEISMICITY 

REVISED MEASURES FROM THE 1997 WATERFRONT PLAN FEIR, AS 
APPROVED BY THE PORT COMMISSION, JUNE 1997 (Included in the Project) 

G.l A geotechnical investigation should be conducted under the direction of a Geotechnical Engineer 
prior to permitting any new construction, including construction of the proposed Illinois Street 
bridge, or reuse of an existing structure for new uses that could increase the load of the structure so 
as to trigger the requirements of Section 3403.6 of the San Francisco Building Code. The 
investigation should be performed to evaluate subsurface conditions and existing foundation 
conditions at the site. The geotechnical investigation should evaluate the potential hazards such as 
settlement, ground shaking, ground rupture, liquefaction, subsidence, slope stability, and lateral 
spreading. Recommendations to mitigate geologic hazards should be made to the project's 
structural engineer regarding the design of new foundations, upgrading of existing foundations, 
seismic design, and mitigation of geologic hazards. ( 1997 FEIR Measure I-l ) 

G.2 To minimize hazards to building occupants from non-structural damage, the Port should require all 
Port facilities and tenants to carry out the following measures at a minimum: heavy objects should 
be attached to secure walls and floors, and light, loose objects should be placed to minimize their 
potential to move or overturn; large storage containers should not be loosely stacked, and those 
stored on shelves should have appropriate restraints or other means to prevent them from tipping or 
sliding off the shelves. 

Heavy objects like freezers, boilers, chillers, laboratory equipment, battery racks and electrical 
transformers, heavy storage cabinets, tanks, safes, oversize file cabinets, etc., should be firmly 
secured to floors and walls to prevent their falling or sliding. All equipment using natural gas 
should be anchored. Care should be taken to avoid placement of such objects where they could 
topple or move and block exit doors. ( 1997 FEIR Measure I-7b) 

G.3 Because of the large number of employees and visitors in some facilities potentially on-site in an 
earthquake and the likelihood that the facilities will be needed to supply emergency response 
services, high-occupancy facilities should be required to store emergency response supplies and 
equipment on-site for a 72-hour reserve. 

It is likely that emergency response systems in San Francisco and in the Bay Area as a whole 
would be overloaded in the immediate aftermath of a large earthquake. Because of the large 
population that may be present in the Project Area in an earthquake (especially under 
Alternatives A and B), it likely would be necessary for offices, hotels, industrial facilities and 
residents to be relatively self-sufficient for a period of a day or two until supply systems can be 
restored. Observations from large earthquakes, such as Mexico City in 1985 and Kobe in 1995, 
confirm that most supply services for water, power, food and medical supplies would be 
unavailable for a minimum of 72 hours after the earthquake. For this reason, medical supplies 
needed for common earthquake injuries, stretchers, blankets, flashlights and at least 72 hours' 
potable water and non-perishable food supply should be stored at easily accessible locations in 
offices, business complexes, hotels and large residential structures. Heavy crow-bars, other heavy 
tools, and hand-operated loudspeakers should be kept in easily accessible and well-marked 
locations in every building and in large parking structures. ( 1997 FEIR Measure I-7c) 

G.4 Non-structural interior elements (ceilings, partitions, light fixtures, HVAC, pipes, etc.) should be 
designed to withstand strong ground shaking and remain intact. This would be accomplished, for 



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example, by selecting lightweight materials and firmly securing them to structural elements of the 
building and by using flexible connections for pipes. ( 7997 FEIR Measure I-7d) 

G.5 Require the use of flexible utility connections and fasten water heaters to walls. Require the 

installation of automatic shut-off valves in all natural gas pipelines and provide similar emergency 
shut-off valves for other gas (oxygen and nitrogen) systems or as otherwise required by the 
San Francisco Fire Department or the Port fire marshal. Do not install automatic shut-off valves 
for water supplies. Require the posting of room/building layout diagrams that indicate the location 
of shut-off valves for natural gas. ( 1997 FEIR Measure I-7e) 

G.6 Require fire extinguishers in all rooms and hallways and adjacent to all exit doors (including 

stairwell exits), as required by the San Francisco Fire Code. Require that cabinets are not placed 
where they could overturn and block access to fire extinguishers. Require the training of all staff 
of offices, hotels, industrial facilities, restaurants and entertainment complexes in the use of fire 
extinguishers. ( 1997 FEIR Measure I-7f) 

G.7 The Port has prepared an earthquake preparedness plan and an earthquake response plan for its 

facilities. The Port shall assist its tenants in preparing earthquake preparedness and response plans 
covering all uses with more than 100 employees and public uses accommodating more than 
100 persons, in compliance with San Francisco Fire Department requirements. ( 1997 FEIR 
Measure 1-7 g) 

Some of the key provisions of an earthquake preparedness plan include the following: 

• Assign responsibilities for disaster control, including primary responsible individuals and 
back-ups. 

• Ensure that individuals with assigned responsibilities are aware of their proper roles (e.g., 
medical response, fire response and coordination with the Fire Department, locating the 
whereabouts of all individuals within an assigned area/unit, conducting periodic inspections 
to reduce earthquake hazards within individual work areas, and maintaining a stock of 
necessary emergency response supplies and equipment). 

• Train all employees in self-protective behavioral response during an earthquake. Train all 
employees in the use of fire extinguishers. 

• Inform all employees about the location of emergency response equipment and supplies. 

• Train all employees to report to an emergency supervisor at a designated safe location 
immediately after an earthquake. 

• Provide free and accessible general first aid training. Training for injuries related to spills of 
hazardous substances during an earthquake is included in OSHA-required Contingency 
Plans. 

• Conduct an earthquake drill at least once a year. 

Some elements of an emergency response plan include the following: 

• Assign all employees a predesignated place and individual to report to immediately after an 
earthquake. 

• Establish a search and rescue plan within designated areas. 

• Establish designated areas at or near the ground floor for short-term occupancy by 
employees or, alternatively, set up shelters in outside areas in a safe place. 

• Provide battery-operated radios and televisions in these areas. 



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• Establish a chain-of-command and operations center for dealing with fires, spills, and 
damaged structures. 

• Assign individuals to coordinate with the Fire Department if they arrive on-site to respond to 
a fire. The Fire Department may have additional requirements for emergency preparedness 
and response. 

• Design response plans for an objective of near-regular medical service capability. ( 1997 
FEIR Measures I-7g and I-7h) 

While earthquake hazards could not be entirely eliminated, implementation of Measures G.2 
through G.8 would reduce the hazards of an earthquake to an acceptable level of risk, within the 
requirements of the City of San Francisco. 

G.8 The Port should take feasible steps to minimize potential earthquake safety risks related to 
hazardous materials in its operations and that of its tenants. 

Specific steps may include appropriate seismic safety provisions, such as prohibiting the storage of 
hazardous materials in containers above head level (about five feet); anchoring hazardous 
materials shelves and heavy equipment to walls and floors; constructing heavy doors that are 
designed to remain shut during earthquake vibrations; providing hand-operable closures for vents 
and air ducts; and other provisions as discussed in the Association of Bay Area Governments' 
Hazardous Material Problems in Earthquakes: A Guide to Their Cause and Mitigation. Other 
measures should be implemented as recommended by the San Francisco Fire Department and/or 
Health Department. Additionally, The Port has prepared an Emergency Procedures Manual for 
Port operations and periodically revise it to be consistent with changes in the facilities and 
operations. Tenants who use or store hazardous materials are required by the local Hazardous 
Materials Ordinance to develop a hazardous materials Business Plan, which includes emergency 
procedures. ( 1997 FEIR Measure I-8a) 

G.9 The Port should require tenants to design all facilities for storage of hazardous chemicals in 

containers, such as cabinets, shelves, and drawers, to minimize potential hazards in an earthquake, 
in accordance with Fire Department and/or Health Department requirements. 

Storage facilities should include safety lips to qontain spills and to reduce the likelihood of 
contents falling. All shelves and cabinets should be secured to a wall or ceiling. All cabinets and 
drawers should be provided with positive latches that would not open during earthquake motions 
and vibrations. Compressed gas cylinders, including empty ones, should be secured to fixed 
features. Gas cylinders should be secured at two locations along their vertical axis, one in the top 
one-third of the cylinder and another in the bottom third of the cylinder. 

The Port should require storage of hazardous chemicals in approved containers and separation of 
incompatible chemicals in separate storage areas. If chemical storage is vented by an electric fan, 
an alternative (emergency) means of ventilation should be provided, which may be a mechanical 
(non-powered) vent. ( 1997 FEIR Measure I-8b) 

Implementation of Measures G.9 and G.IO would reduce hazardous materials-related non- 
structural safety hazards of an earthquake to an acceptable level of risk. 

G.IO Project sponsors, including the Port, should employ an engineer qualified in earthquake 

engineering to incorporate into the final design of individual facilities developed under the WLUP 
all economically feasible engineering methods to reduce the potential for loss of life-line services. 
This may include methods to improve unstable ground conditions, to strengthen infrastructure to 
be more resistant to earthquake induced graund movements, and to organize and prepare for 



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earthquake response. While specialized techniques for ground improvement to reduce liquefaction 
hazards likely are not practical or economically feasible over large areas, ground improvements 
within selected strategic sites may result in substantial hazard reduction to utility systems. In such 
areas a variety of ground stabilization techniques may be considered, such as compaction grouting, 
placement of stone columns, and deep soil mixing. ( 1997 FEIR Measure I-9a, Revised) 

G.ll For individual development projects, the use of flexible connections for utility lines may be needed 
(see Mitigation Measure G.7). Back-up supplies of water, power generators, and battery-operated 
telecommunications equipment may need to be installed (or enlarged at the existing facilities). 
The engineer should recommend the appropriate approach (e.g., separate facilities and equipment 
or upgrading existing facilities) for all Project Area facilities. ( 1997 FEIR Measure I-9b) 

G.12 The Port, in cooperation and compliance with the City's Office of Emergency Services, Fire 
Department and Police Department, should plan routes of alternative emergency access to 
development sites. 

Available routing for emergency response vehicles needs to be quickly assessed following an 
earthquake and conveyed immediately to ambulance drivers, fire persons and police officers. 
Consistent with the City's Civil Defense and Disaster Operation Plan, information should be 
provided about routing to hospitals including consideration of streets blocked by debris, collapsed 
or unsafe bridges, and streets rendered impassable by road damage. To prepare for such possible 
loss of access, the City should consider developing alternative routing concepts to reach the 
hospitals and familiarize ambulance drivers, fire persons and police with the altemates. ( 7997 
FEIR Measure I-9c) 

G.13 An inspection schedule should be developed and followed for regular inspection and evaluation of 
the condition of the piers. In conjunction with the inspection schedule, a maintenance and repair 
schedule should be developed and implemented, coordinated with the Port's Capital Plan. ( 7997 
FEIR Measure I-lOa) 

G-14 All open sub-grade structures and pits, whether temporary or permanent, should be provided with 
protection against damage resulting from adjustment to buoyant and lateral deforming soils. 

All construction and design of such projects should provide specific measures to prevent hazards 
to people and damage to proposed or nearby structures that could result from these adjustments. In 
some cases, a specific geotechnical investigation may be required for permanent open sub-grade 
structures and open underground structures. ( 1997 FEIR Measure 1-2) 

G-15 Prior to any construction that would require dewatering, the applicant should submit and the Port 
should review a dewatering and excavation plan and an analysis of potential impact to adjacent 
properties to determine whether the potential exists to damage off-site property. 

As a standard practice, the Port should require an application package that will indicate the amount 
of dewatering and the period over which dewatering may be required. The package should include 
a survey of adjacent structures with information concerning their age, foundation type, 
construction type, status as a historic landmark or structure of special significance, and record of 
any existing damage. The package should also identify adjacent City streets, the location of buried 
infrastructure, and an evaluation of groundwater quality, flow patterns, and disposal. In addition, 
the application should indicate any specific mitigation measures incorporated into the project to 
minimize hazards to structures and groundwater. ( 7997 FEIR Measure I-3a) 



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G-16 To minimize dewatering hazards, construction projects should provide shoring of all excavation pit 
walls, and provide supports to adjacent structures, including foundation support if needed. ( 1997 
FEIR Measure I-3b) 

G-17 All applicants for construction projects involving dewatering (as well as vibration-inducing pile 
driving) should post a surety bond or other equivalent mechanism to cover the costs of potential 
damage to off-site property from construction. (The bond is included in this EIR as a mitigation 
measure because of the uncertainty that other mitigation measures would protect off-site property 
from damage. If needed, the bond would be used to repair off-site damage and thus mitigate that 
impact.) The amount of the bond would be determined by the Port. ( 1997 FEIR Measure I-3c) 

G-18 Prior to any construction that would require dewatering or pile driving, the Port should notify all 
property owners within 200 feet of the proposed construction activity at least 30 days prior to the 
date of initiating demolition or excavation, whichever is the first activity to occur. The Port should 
provide an opportunity for all property owners to comment on the construction activity and allow 
them the opportunity to have their property photo-documented for its pre-construction condition. 
The Port is responsible for inspection of construction activities and should note any observations 
of proven or suspected subsidence damage on the site and at adjacent sites. This measure would 
allow adjacent property owners to document the condition of their property prior to initiation of an 
activity that could result in damage. If damage does occur, the measure would help to identify the 
extent of the damage caused by construction within the Project Area. ( 7997 FEIR Measure I-3d) 

G-19 For impacts from pile driving, the Port and project sponsors should implement Measures G-16 
through G-19. (7997 FEIR Measure 1-4) 

G-20 Proposed new dredging activities (deeper than the designed depth or in different locations than 

ongoing maintenance dredging) should be reviewed by an engineering geologist to assess potential 
hazards to Port facilities. Dredging programs in areas with a past history or high potential for 
lateral movement of Bay Mud should be designed to hold a slope without readjustment or slippage. 
(This measure would apply to suction and clamshell dredging.) 

To minimize slope failure in the Bay sediments, dredged cuts should be properly designed and 
dredged, as recommended by the engineering geologist. Typically, subestuarine slopes in soft Bay 
sediments are cut at 3:1 to 6: 1 (horizontal to vertical ratio).'*^ ( 7997 FEIR Measure 1-5) 

G-21 If demolition is not immediately followed by redevelopment, the Port or project sponsor, as 

determined by the Port, should carry out effective measures that leave the site of all demolished 
buildings in a condition that will not pose a life safety hazard or potential to damage adjacent 
properties. 

Such measures should include removal and or proper sealing of pipes (including water, gas, and 
sewer lines), establishment of effective shoring or construction of retaining walls for unstable pit 
walls, filling of basements that create hazardous conditions, removal of hazardous substances, and 
other measures as deemed appropriate at a specific site, such as fencing. The Port would be 
responsible for vacant lands that may include the hazards identified in the Geology, Soils and 



U.S. Department of the Navy, Western Division, Naval Hecilities Engineering Command, EIS: Homeporting Battleship 
Battlegroup/Cruiser Destroyer Group, p. 7-4, 1987. 



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Seismicity section of the WLUP FEIR. The above measures are minimum requirements to ensure 
that hazards would be held at acceptable levels until such time as land development could occur. 
The Port would be responsible for carrying out the mitigation or overseeing compliance with it. 
(7997 FEIR Measure 1-6) 

H. HISTORIC ARCHITECTURAL RESOURCES 

REVISED MEASURE FROM THE 1997 WATERFRONT PLAN FEIR 
IDENTIFIED IN THIS SEIR 

The Waterfront Plan FEIR included an historic resources survey in the Pier 70 area (ARG, 1996). That 
survey identified Building 6, proposed for reuse by Waste Resources Technologies, as a potential 
contributor to a potential Pier 70 historic district. Accordingly, the following more specific measure 
supplements the general measures included in the 1997 FEIR (which shall continue to apply to other 
buildings in the Pier 70 area). 

H. l To avoid adverse effects on the potential historic district at Pier 70, the Port should ensure that a 

qualified historic preservation architect reviews the proposed renovation plans for Building 6 at 
Pier 70 prior to issuance of any demolition or building permit for the project component that would 
reuse this building. To the extent that exterior changes are to be made to Building 6, these changes 
should be consistent with the maritime/industrial character of the Pier 70 area, particularly with 
regard to the rear of the building, abutting Michigan Street, consistent with the Waterfront Plan 
Design and Access Element direction to preserve views of the historic warehouses (including 
Building 6). 

I. ARCHAEOLOGICAL RESOURCES 

REVISED MEASURE FROM THE 1997 WATERFRONT PLAN FEIR, AS 
APPROVED BY THE PORT COMMISSION, JUNE 1997 (Included in the Project) 

I.l. Given the possibility that subsurface archaeological resources exist in the Southern Waterfront 
project area, yet the inherent uncertainty about the specific locations and scope of such buried 
resources, the Port or sponsor of individual future project(s), as determined by the Port, shall retain 
an archaeologist as early as is practical in the site selection or schematic design stage of future 
development project(s) that would involve excavation or other substantial soil disturbance of 
greater than four feet in depth. The archaeologist would prepare a brief preliminary site-specific 
evaluation or letter report, based on existing archival report information, assessing the 
archaeological sensitivity of the specific site(s) under consideration relative to the scope of 
excavation proposed. The archaeologist would consider the history of fill soils on the site(s) in the 
assessment of the potential for significant archaeological resources to exist and be disturbed or 
destroyed by the contemplated project, and make recommendations on subsequent actions 
designed to ensure the protection of potentially significant resources. 

Based on the initial site-specific report, the archaeologist and the Environmental Review Officer 
(ERO) would determine whether a more detailed site assessment is warranted, the results of which 
could include an appropriate course of action necessary to minimize the disturbance to significant 



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archaeological resources, and/or maximize information recovery where such disturbance cannot be 
avoided. Depending on the expected sensitivity of the area to be excavated, this could include a 
program of pre-construction testing, excavation monitoring, or both. If the ERO concurs with a 
preliminary evaluation determining that a project site has no potential to contain significant 
archaeological resources that could be impacted by a proposed development (which may 
commonly occur in the areas of recent fill or disturbance, such as most of the waterfront south of 
China Basin), then this measure would be satisfied and archaeological issues would no longer be a 
concern for that particular development project. 

If, based on the likelihood of encountering significant archaeological resources as identified in the 
site assessment report(s), the archaeologist and the ERO determine that pre-construction testing is 
warranted to better determine the probability of finding cultural remains, the sponsor would retain 
the services of an archaeologist familiar with prehistoric and urban historical archaeology, and 
San Francisco specifically. The archaeologist would carry out a pre-excavation testing program 
using a series of mechanical, exploratory borings or trenches and/or other testing methods 
determined by the archaeologist and the ERO to be appropriate. 

If, after testing, the archaeologist determines that no further investigations or precautions are 
necessary to safeguard potentially significant archaeological resources, the archaeologist would 
submit a written report to the ERO, with a copy to the project sponsor. If the archaeologist 
determines that further investigations or precautions are necessary, he/she should consult with the 
ERO and they should jointly determine what additional procedures are necessary to minimize 
potential effects on archaeological resources. 

These additional mitigation measures would be implemented by the project sponsor and might 
include a program of on-site monitoring of all site excavation, during which the archaeologist 
would record observations in a permanent log. The monitoring program, whether or not there are 
finds of significance, would result in a written report to be submitted first and directly to the ERO, 
with a copy to the project sponsor. During the monitoring program, the project sponsor would 
designate one individual on site as his/her representative. This representative would have the 
authority to direct and suspend work at the site to give the archaeologist time to investigate and 
evaluate archaeological resources should they be encountered. 

Should evidence of cultural resources of potential significance be found during the monitoring 
program, the archaeologist would immediately notify the ERO, and the project sponsor would halt 
any activities which the archaeologist and the ERO jointly determine could damage such cultural 
resources. Ground-disturbing activities which might damage cultural resources would be 
suspended for a total maximum of four weeks over the course of construction. 

If prehistoric archaeological deposits are fortuitously discovered, the California Native American 
Heritage Commission in Sacramento and local Native American organizations should be consulted 
and involved in making resource management decisions. All applicable legal requirements 
concerning the treatment of cultural materials and Native American burials should be enforced. 

After notifying the ERO, the archaeologist would prepare a written report to be submitted first and 
directly to the ERO, with a copy to the project sponsor, which would contain an assessment of the 
potential sigrtificance of the find and recommendations for what measures should be implemented 
to minimize potential effects on archaeological resources. Based on this report, the ERO would 



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recommend specific additional mitigation measures to be implemented by the project sponsor. 
These additional mitigation measures might include a site security program, additional on-site 
investigations by the archaeologist, and/or documentation, preservation, and recovery of cultural 
material. 

Finally, the archaeologist would prepare a report documenting the cultural resources that were 
discovered, an evaluation as to their significance, and a description as to how any archaeological 
testing, exploration and/or recovery program was conducted. 

Copies of all draft reports prepared according to this mitigation measure would be sent first and 
directly to the ERO for review. Following approval by the ERO, copies of the final report would 
be sent to the President of the Landmarks Preservation Advisory Board and the California 
Historical Resources Information System Northwest Information Center. Three copies of the final 
archaeology report(s) shall be submitted to the Office of Major Environmental Analysis of the 
Planning Department, accompanied by copies of the transmittals documenting its distribution to 
the President of the Landmarks Preservation Advisory Board and the California Archaeological 
Site Survey Northwest Information Center. ( 1997 FEIR Measure 0-1 b) 

Based on the descriptions of the Industry Group project components and the proposed Illinois Street 
bridge, minimal excavation would be required, and none of these project components would appear to 
have the potential to disturb subsurface cultural resources, should such resources be present at a 
particular project component site. Measure 1. 1 above would apply, however, to future Port development. 

J. MEASURES FROM THE 1997 WATERFRONT PLAN FEIR NOT 
APPLICABLE TO THE PROJECT ANALYZED IN THIS SEIR 

TRANSPORTATION 

• Under Alternative A for the weekday P.M. peak hour, the intersection of The Embarcadero and 
Bay Street would be at LOS E, an unacceptable service level. A right turn arrow for the Bay Street 
approach to the intersection would improve this condition to LOS D, an acceptable level of 
service. (1997 FEIR Measure D-1 ) 

• Under Alternative B for the weekday P.M. peak hour and during the Saturday midday peak hour, 
the intersection of The Embarcadero and Bay Street would operate at LOS F, an unacceptable 
service level. A right turn arrow for the Bay Street approach to the intersection eastbound would 
improve weekday P.M. peak hour delay time by about 40 seconds; however, the LOS would 
remain at F. With the right turn arrow, the Saturday midday peak hour service level would 
improve from LOS F to D, an acceptable service level. ( 7997 FEIR Measure D-2) 

• Also under Alternative B for the weekday P.M. peak hour, the intersection of The Embarcadero 
and North Point would operate at LOS E. Providing a right turn pocket, by removing two to three 
parking spaces and removing the red zone along the southern edge of North Point Street 
approaching the intersection (assuming this bus stop will not be needed in the future with the F- 
line operation), would improve this intersection to LOS D. ( 1997 FEIR Measure D-3) 



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J. MEASURES FROM 1997 FEIR BUT NOT APPLICABLE 



• To reduce vehicular traffic, and to accommodate demand for transit along The Embarcadero 
generated by Alternative B, additional transit capacity along The Embarcadero (with direct 
connection between Fisherman's Wharf and the South Beach/China Basin subareas) would be 
needed, particularly on weekends. Ideally, additional Muni service (e.g., additional F-Line 
streetcars, continual service along the full length of The Embarcadero [formerly proposed as the E- 
Line], F-Line supplemented by reinstating 32-Embarcadero bus service, or some combination of 
these) should be provided. If conditions warrant such additional transit capacity, the Port and/or its 
tenants should provide financial assistance to Muni for both capital and operating costs. If 
augmentation of Muni service is determined to be infeasible, and/or the degree of augmented Muni 
service is not sufficient to meet demand, the Port and/or its tenants could institute private transit 
shuttle services along The Embarcadero with stops located to increase accessibility to and the 
attractiveness of regional transit (e.g. BART, Caltrain, SamTrans and ferries). (1997 FEIR 
Measure D-5) 

• Under Alternative B significant numbers of short transit trips along The Embarcadero north of the 
Ferry Building are forecast, which would primarily have an impact on the Muni F-Line, 
particularly on weekends. Alternative B would also generate new demand for Muni service that 
could cause significant congestion on individual lines City wide. Muni may not have sufficient 
operating funds to provide additional seating capacity over that currently projected. Several 
options are available to help mitigate this impact. 

A. The Transit Impact Development Fee Ordinance currently is applicable only to net new 
office development within a specific geographic area. The Ordinance could be amended to 
specifically apply to development within the Project Area, although the amount of net new 
office growth in the Project Area would not be large and thus would provide limited 
additional revenue to Muni to help support additional transit service on The Embarcadero. 
The TIDF could also be amended to be more inclusive in terms of the land uses that would 
trigger imposition of the fee on a developer, while continuing to be related primarily to 
special (extraordinary) demand for peak period service. 

B. A new funding mechanism for Muni could be enacted, such as a Special Transit Assessment 
District. Various proposals for alternative funding mechanisms have been put forward in the 
past. The Port should actively support future proposals which are designed to provide 
additional operating and capital resources to Muni, including any future local proposals for a 
special district, tax or fee that would support Muni services, and any future proposals before 
the State and federal legislatures which would provide additional financial resources to Muni 
for both operations and capital projects. The Port could also be an advocate for specific 
transit capital projects that would enhance Muni service to the Project Area. 

C. The San Francisco half-cent sales tax for transportation expires in the year 2009. The 
Transportation Expenditure Plan establishes a prioritized list of specific projects for use of 
these funds. It is possible, if not likely, that the San Francisco County Transportation 
Authority, which administers the sales tax funds, may seek reauthorization of the sales tax 
prior to its expiration. A new Transportation Expenditure Plan would need to be prepared to 
support such reauthorization. The Port should actively support identification of specific 
transit improvements along the waterfront which could help mitigate unmet transit demand 
identififed in this EIR as a component of this Expenditure Plan. 



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D. The Port and/or its tenants could directly provide funds to Muni for additional waterfront 
transit service. Such direct payment to Muni might be partially financed from additional 
revenues to the Port resulting from Waterfront Land Use Plan (WLUP) development. ( 1997 
FEIR Measure D-6) 



VISUAL QUALITY 

Subsequent to certification of the 1997 Waterfront Plan FEIR and adoption of the Waterfront Land 
Use Plan, the Port adopted design guidelines for the waterfront. The Waterfront Plan's Design and 
Access Element includes language calling for preservation of historic resources, including - in the 
Southern Waterfront Area - the principal Union Works Buildings at Pier 70 (Buildings 101, 102, 
and 104 on the north side of 20th Street east of Illinois Street, and, if feasible. Buildings 1 13-1 14 
on the south side of 20th Street). The Design and Access Element states also that "additional 
Pier 70 resources may be identified for preservation following further research and analysis of 
Pier 70' s periods of historical significance and the feasibility of reusing individual buildings." 
Outside the Southern Waterfront, the Port is considering nominating historic buildings along the 
waterfront from China Basin north to Fisherman's Wharf as National Register Historic District. 
Accordingly, visual quality mitigation measures from the 1997 WLUP FEIR have largely been 
completed. The Port is required to consider visual quality objectives early in the development of 
proposed projects, evaluate projects against standards in the Design and Access Element, and 
ensure that project approvals are consistent with the adopted standards. 



GEOLOGY, SOILS, AND SEISMICITY 

• New high-occupancy mid-rise structures (i.e., on the order of 6 to 15 stories) in the Project Area 
should be designed with the aid of a dynamic method analysis. The Port should consider 
establishing specific building design criteria developed by a task force of structural engineers to 
determine which types of structures (considering framing system, foundation, height and massing) 
should be designed using a dynamic method analysis and adopt this requirement as a Waterfront 
Land Use Plan policy. 

The severe ground shaking hazards of Port lands indicate that large structures (including high- 
occupancy mid-rise structures) should be designed to meet seismic resistance standards greater 
than the minimum standards in the UBC. The UBC does not require this except for certain 
buildings (none of which are specifically identified in the Waterfront Land Use Plan, although the 
Ferry Terminal is being designed as an "essential structure," to more stringent earthquake force 
design requirements. Fire and police stations, hospitals and schools also would be essential 
structures). Currently, the best available method for achieving this end is the use of a dynamic 
method analysis for the design of the buildings. This method incorporates a consideration of the 
response of the site soils to earthquakes generated in the region. For each building, the site 
response spectra are modeled and incorporated into the structural design. As noted in the Geology, 
Soils and Seismicity of the WLUP FEIR, the entire Project Area should be considered part of a 
"special studies zone" in which the severe earthquake hazards of ground shaking and secondary 
effects are evaluated and incorporated into structural designs. Use of a dynamic method analysis 
substantially enhances the chances that the new building would be more resistant to collapse and 
damage from a major earthquake than if it meets only the minimum UBC requirements. The 
higher costs associated with using the method and applying it in design and construction likely are 



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J. MEASURES FROM 1997 FEIR BUT NOT APPLICABLE 

significantly less than those that would result from a building being red-tagged or required to 
undergo substantial repair following a major earthquake. (7997 FEIR Measure I-7a) 

• Piers that are in poor condition should be repaired or demolished and removed. If repaired, piles 
that are deteriorated should be replaced or the portion that is rotted or deteriorated should be cut 
off and replaced with a concrete steel sleeve. A structural engineer should be consulted regarding 
the repair of the piers. ( 1997 FEIR Measure I-lOb) 

• At the time of anticipated tsunami incursion, the San Francisco Police Department should close off 
the immediate waterfront area of Aquatic Park, Fisherman's Wharf and the Hyde Street Pier to the 
public; all marina operators should close off access to the docks for the public and boat owners; 
and ferry boat operators should prevent people from standing on water-level ferry loading docks 
everywhere in the Project Area. ( 7997 F£"77? Measure I-lla) 

This mitigation measure would help to reduce the potential for casualties to occur from tsunami by 
keeping people away from areas where injury could occur. Damage to facilities would not be 
mitigated. 

• To reduce potential damage to facilities from tsunami, consider constructing larger and higher 
breakwaters at the Hyde Street Pier, Fisherman's Wharf and marinas. The infrequency of tsunami 
may not warrant the cost and environmental impact of breakwater reconstruction. (7997 FEIR 
Measure l-llb) 



REFERENCES - Mitigation Measures 

ARG (Architectural Resources Group), "Port of San Francisco Historic Resources Data B." 
November 1996. . 

Stormwater Quality Task Force, Industrial/Commercial Best Management Practices Handbook, prepared 
by Camp Dresser & McKee, et. al., March 1993. 



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CHAPTER V 



SIGNIFICANT ENVIRONMENTAL EFFECTS 

In accordance with Section 21067 of the California Environmental Quality Act (CEQA), and with 
Sections 15040, 15081 and 15082 of the State CEQA Guidelines, the purpose of this chapter is to 
identify environmental impacts that could not be eliminated or reduced to an insignificant level by 
mitigation measures included as part of the project, or by other mitigation measures that could be 
implemented, as described in Chapter IV, Mitigation Measures, pp. 143-164. Findings in this chapter are 
subject to final determination by the Planning Commission as part of its certification of the SEIR. 

The project would result in significant, unmitigable traffic congestion at selected local intersections. The 
project also would result in total project emissions of criteria air pollutants on a region-wide basis that 
would exceed Bay Area Air Quality Management District project-specific thresholds and would 
therefore be considered significant and unmitigable, and would contribute to potentially significant 
cumulative air emissions from existing (unquantified) and possible future (unknown) sources in the 
greater site vicinity. 

Specifically, traffic congestion at four intersections would not be mitigable with the addition of traffic 
from both phases of the proposed project in 2015. These intersections are: 

> Mariposa Street / 1-280 southbound on-ramp (LOS F in a.m. peak hour; LOS E in p.m. peak hour); 

> Mariposa Street / 1-280 northbound off-ramp (LOS F in a.m. peak hour; LOS E in p.m. peak hour); 

> Third / Mariposa Streets (LOS E in a.m. and p.m. peak hours); and 

> Evans Avenue / Cesar Chavez Street (LOS F in a.m. peak hour). 

Project-generated maximum daily emissions of reactive organic gases (ROG), nitrogen dioxide (NO^^), 
and respirable particulates (PM-10) from all project components combined would exceed the 
significance threshold of 80 pounds per day in both 2003 and 2015. The significance threshold for 
annual emissions of 15 tons per year would also be exceeded for ROG and NO^ in each year. Therefore, 
the project would result in a significant effect with regard to emissions of criteria pollutants. This 
significant impact would occur regionally, and would not be directly reflective of local conditions in the 
immediate vicinity of the project. (As discussed in the local air quality analysis on p. 89, localized 
emissions concentrations would not be significant). This significant regional impact cannot be reduced 
to a less-than-significant level because of the magnitude of the project. 



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The project would also contribute to a potentially significant cumulative regional impact on air quality 
because daily and annual volumes of criteria pollutants would exceed Bay Area Air Quality Management 
District (and SEIR) project-specific significance thresholds as described above. Locally, cumulative 
carbon monoxide concentrations would be less than significant. However, cumulative concentrations of 
PM-10 and diesel particulate cannot be quantified because of the multitude of existing sources. 
Therefore, to be conservative, these emissions are deemed cumulatively significant, although the project 
itself would not have a significant effect with regard to local concentrations of PM-10 or diesel 
particulate. 



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CHAPTER VI 



ALTERNATIVES TO THE PROPOSED PROJECT 

As described in the Waterfront Land Use Plan EIR, market conditions and other factors will determine 
the nature of development that occurs along the waterfront, consistent with provisions of the Waterfront 
Plan. Alternative buildout scenarios were analyzed fully in the Waterfront Plan EIR, and are 
incorporated herein by reference. In addition, this chapter describes alternatives to the project analyzed 
in this Supplemental EIR, and thereby provides further specificity regarding the range of alternatives that 
could occur in the Southern Waterfront subarea under the Waterfront Land Use Plan. Project decision- 
makers must adopt and implement one of the following alternatives, in lieu of approving the project, if 
the alternatives are determined feasible and if they would substantially lessen or avoid significant 
environmental effects of the proposed project. 

In preparing this Supplemental EIR, staff of the Planning Department and the Port considered carefully 
whether alternative sites are available that could potentially accommodate the entirety of the project and 
eliminate potentially significant effects identified. San Francisco has a limited supply of industrially 
zoned land that could accommodate components of the project such as the Industry Group uses, and also 
has a limited supply of land that can accommodate both marine and rail transport. This supply of land is 
located entirely within the southeastern quadrant of the City, and thus the staff concluded that even if an 
alternative site could be identified, its use would not eliminate significant impacts associated with the 
project. For example, traffic impacts of project uses would likely affect many of the same intersections 
examined in this SEIR, and particularly those where significant unavoidable effects were identified, 
because those intersections are along key routes through the southeastern portion of San Francisco. With 
regard to air quality, the project's significant unmitigable effects would occur with regard to regional air 
quality, and would therefore be little affected by a shift to other site(s). For these reasons, the 
altematives analysis presented below delineates a range of possible intensities that could occur in the 
Southern Waterfront subarea, including altematives that would delete or modify components and land 
uses within the project description. In addition to those altematives explicitly described and analyzed 
below, altematives that rearrange components of the project within the site area could be considered by 
the decision-makers, along with altematives that would delete or modify other components and land uses 
within the project, as long as no new significant environmental impacts would result. 



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A. ALTERNATIVE A: NO PROJECT 

DESCRIPTION 

This alternative would entail no change to the project area, which would remain in its existing condition. 
None of the Industry Group project components would be implemented, and the Illinois Street 
Multimodal Bridge would not be built. Because several of the Industry Group components are proposed 
in response to the need for Industry Group members to relocate from existing locations, this alternative 
would necessarily involve displacement of those uses elsewhere in San Francisco, including the existing 
Bode Gravel and RMC Pacific concrete plants and the Coach USA bus operation. Those uses could 
relocate elsewhere in the City, although particularly in the case of the concrete plants, the potential 
locations are limited by the heavy industrial nature of the uses. It would be speculative, however, to 
project potential relocation sites for these uses, which could be forced to move out of San Francisco 
under this alternative. It should be noted that, if concrete plants were to relocate outside of 
San Francisco, the demand for ready-mix concrete would not be expected to change, since the demand is 
a result of development activity. The result would be longer trips by cement mixers between out-of-City 
plants and construction sites in San Francisco and/or an increase in the use of small on-site "batch 
plants." 

Also under this alternative, the future development envisioned for the Pier 70 Mixed-Use Opportunity 
Area, the Pier 70 Maritime Reserve area, the Pier 90-94 backlands, and the Western Pacific site (except 
for the already approved Muni Light Rail storage and maintenance facility) would not necessarily occur 
as described in this SEIR. There might still be some development on these sites in the future, consistent 
with the Waterfront Land Use Plan, and subsequent environmental review could be required if projects 
were to differ substantially from those described in this document. Increased cargo shipping could also 
occur in the Southern Waterfront, consistent with the Waterfront Plan. 

IMPACTS 

This alternative would result in little or no short-term (Phase I) increase in automobile or truck travel, as 
would occur with implementation of the proposed project. The Phase I adverse impacts on intersections 
would not occur at Third / 25th Streets, Third Street / Cargo Way, and Amador Street / Cargo Way. 
Long-term (2015) effects on local intersections would be less substantial than would occur with the 
project, but could still be significant, depending on the volume of future development on Port lands and 
increased cargo shipping. Long-term future conditions would be similar to those identified in other 
analyses. For example, the intersection of Third and Cesar Chavez Streets would operate at LOS F in the 
p.m. peak hour, as described in the Third Street Light Rail EIS/EIR. Therefore, this alternative would 
result in significant traffic impacts in 2015, although to a lesser degree than would the project. 

Emissions of criteria air pollutants would be less substantial than with the project, particularly in the 
short-term (consistent with Phase I of the project). By 2015, depending on the increase in cargo shipping 
at the Port, emissions of NOx could be significant, as with the project, although the volume of emissions 

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VI. ALTERNATIVES 



would be less. This alternative would also result in a significant cumulative effect related to air quality. 
Like the project, however, this alternative would result in less-than-significant effect with regard to local 
concentrations of carbon monoxide, PM-10, and diesel particulate. 

Effects related to hydrology would be less substantial than those of the project, and would be less than 
significant with the mitigation measures revised from the Waterfront Plan EIR to control stormwater 
runoff. As with transportation and air quality, the precise nature of future development on Port lands and 
the potential future increase in cargo shipping is not known for this alternative, but it is likely that there 
would be some increase in impervious surface that could result in an increase in stormwater runoff to the 
Bay, albeit to a lesser degree than with the project. 

Similarly, the No Project Alternative would result in less potential for exposure to and accidental release 
of hazardous materials than would the project, although any potential impacts would continue to be 
mitigated, as with the project, by reliance on existing regulations, including Article 22A of the City 
Public Health Code. As with the project, impacts would be less than significant with mitigation. 

The No Project Alternative would be environmentally superior to the project because it would avoid 
much of the environmental impact of the project. 

The No Project Alternative would not meet the project objectives. 

B. ALTERNATIVES: REDUCED-SCALE ALTERNATIVE 
DESCRIPTION 

This alternative would include all Industry Group facilities with the exception of the proposed Mission 
Valley Rock asphalt plant and the Coach USA bus storage facility, as well as those shipping-related 
components that are proposed to provide for an anticipated shift in the supply of construction aggregate 
from local sources to out-of-area sources. Included would be two concrete plants (Bode Gravel at 
Pier 92 and RMC Pacific at Pier 80); Mission Valley Rock's aggregate import terminal at Pier 92 (but 
not Mission Valley's proposed asphalt plant; British Pacific Aggregates aggregate shipping and storage 
operation at Pier 94 (but not BPA's potential future concrete and asphalt plants); ISG Resources fiy ash 
storage facility (in the former grain silos at Pier 90); and Waste Resource Technologies' construction 
materials recycling operation at Pier 70. Not included in this alternative would be the Mission Valley 
Rock asphalt plant, the potential future BPA concrete and asphalt plants, or Coach USA's bus storage 
and maintenance facility at Pier 96. Under this alternative, concrete production would remain at the 
2003 level through 2015 (see Appendix A for a discussion of assumptions regarding construction 
aggregate production). 

This alternative would also include construction of the Illinois Street Intermodal Bridge, proposed by the 
Port. However, less future development would occur on other Port lands than with the proposed project. 
Alternative B would include increased cargo shipping at Pier 80 and Piers 94-96, although at a lesser 



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level than would occur with the project; expansion of the Port's dredge material handling site at Pier 94; 
development of the Pier 70 mixed-use opportunity area and the Pier 70 maritime reserve area; and 
development of the Western Pacific property. This alternative does not include development of the 
Piers 90-94 backlands. 



IMPACTS 

This alternative would result in less traffic generation, particularly with Phase II (2015) development, 
than would the project. With this alternative. Phase I daily vehicle trip generation would be about 
20 percent less than with the project (Industry Group vehicle trip generation would be about 30 percent 
less than with the project). In 2015, Phase II daily vehicle trip generation would be almost 35 percent 
less than with the project. The decrease in peak-hour trip generation, compared to that with the project, 
would be even greater - about 50 percent in the a.m. peak hour and about 85 percent in the p.m. peak 
hour. 

Because Phase I of the project would not result in any significant unavoidable traffic impacts, 
intersection levels of service for Alternative B were evaluated for Phase II only. With this alternative's 
decreased traffic volumes, compared to the project, intersection levels of service would be improved, 
compared to conditions with Phase II project development. In the a.m. peak hour, only two intersections 
would operate at LOS F - Mariposa Street at the southbound 1-280 on-ramp and at the northbound 1-280 
off-ramp. These intersections would also be at LOS F with the project. Three other intersections would 
operate at LOS E. Impacts could be mitigated at one of these five intersections. Three other 
intersections that would operate at LOS F with the project would instead operate at LOS D or better with 
Alternative B. In the p.m. peak hour, only three intersections would operate at LOS E or F under 
Alternative B, compared to 1 1 intersections with the project. Impacts at these three intersections could 
be mitigated to LOS D or better. Thus, like the proposed project. Alternative B would result in 
significant unavoidable traffic impacts, although the impacts would be less substantial than those with 
the project. Level of service results are shown in Table 24. 

Near-term air quality impacts (2003) would be similar to, but slightly less than, those identified for the 
project, because the overall level of activity in Phase I would be similar under this alternative to that with 
the project. By 2015, the overall emissions of criteria pollutants generated by this alternative would be 
reduced, compared to the project. In particular, annual emissions of NO^ from future cargo shipping 
activity at the Port would be about half of those with the project, because the annual volume of cargo 
handled would be about half that with the project. However, criteria pollutant emissions would not be 
reduced to a less-than-significant level, and would be significant, as with the project. Local air quality 
impacts (concentrations of carbon monoxide, respirable particulate matter, and diesel particulate) would 
be less-than-significant, as with the project, and would be would be incrementally less substantial. 
Cumulative air quality effects would remain significant, although this alternative's contribution would be 
less than that of the project. 



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TABLE 24 

TRAFFIC LEVELS OF SERVICE FOR ALTERNATIVE B 



A.M. Peak Hour 
2015 + Alternative B 
Project (2015) 
LOS Delay LOS Delay 



P.M. Peak Hour 
2015 + Alternative B 
Project (2015) 
LOS Delay LOS Delay 



Intersection 



1-280 SB on- ramp/ Mariposa Street 


FV 


>60 


F V 


>60 


E V 


46.2 


D 


30.7 


1-280 NB off-ramp/ Mariposa Street 


F 


>60 


F V 


>60 


E 


42.1 


D 


39.3 


Minnesota / Mariposa Streets 


B V 


13.9 


B 


14.0 


c V 


15.9 


C 


16.1 


Third / Mariposa Streets 


E 


59.1 


E 


41.2 


E 


56.4 


D 


35.0 


Illinois / Mariposa Streets 


D 


25.1 


D 


25.1 


D 


21.5 


D 


21.5 


Third / 20th Streets 


D 


37.5 


C 


19.7 


D 


37.2 


C 


20.9 


Illinois / 20th Streets 


C 


17.3 


C 


17.3 


C 


11.0 


C 


11.0 


Third / 25th Streets 


D 


28.6 


C 


18.2 


F 


>60 


F 


>60 


Mitigated Level of Service (2015) 


N/A 


N/A 


N/A 


N/A 


D 


34.1 


D 


<34.1 


Illinois / 25th Streets t 


B(C) 


9.3 


A(B) 


4.3 


F 


>60 


A(B) 


3.5 


Mitigated Level of Service (2015) 


N/A 


N/A 


N/A 


N/A 


A 


4.3 


N/A 


N/A 


Pennsylvania / 1-280 SB on-ramp $ 


B(C) 


5.3 


A(B) 


3.1 


E(F) 


40.9 


A(B) 


4.4 


Mitigated Level of Service (2015) 


N/A 


N/A 


N/A 


N/A 


B 


8.5 


N/A 


N/A 


Evans Av. / Cesar Chavez St. 


F 


>60 


E 


42.2 


D 


36.9 


C 


23.6 


Pennsylvania / Cesar Chavez Streets 


F 


>60 


D 


39.8 


F 


>60 


E 


57.6 


Mitigated Level of Service (2015) 


D 


26.7 


N/A 


N/A 


D 


32.6 


D 


<32.6 


Third / Cesar Chavez Streets 


F 


>60 


E 


56.5 


F 


>60 


F 


>60 


Mitigated Level of Service (2015) 


D 




D 




D 




D 




Illinois / Cesar Chavez Streets t 


F 


>60 


B(C) 


5.8 


F 


>60 


A(C) 


3.4 


Mitigated Level of Service (2015) 


D 


32.6 


N/A 


N/A 


B 


77.5 


N/A 


N/A 


Third Street / Cargo Way 


C 


18.7 


C 


18.6 


D 


38.9 


D 


38.6 


Amador Street / Cargo Way t 


F 


>60 


B(D) 


7.2 


F 


>60 


A(C) 


2.0 


Mitigated Level of Service (2015) 


C 


75.7 


N/A 


N/A 


B 


14.4 


N/A 


N/A 


Third Street / Evans Avenue 


D 


37.3 


D 


27.9 


D 


34.4 


D 


32.6 



KEY: LOS = Level of Service; Delay = Delay in average seconds per vehicle. Where delay is in excess of 60 seconds, the 
notation ">60" is used; beyond 60 seconds, measurement of average delay becomes unreliable. 

t - Unsignalized intersection. LOS and delay reported for overall intersection; LOS in parentheses is for critical movement 

(normally, minor street left-turn), when worse than overall LOS. Where previously approved signaiization is to occur in the 
future, symbol is used with LOS for individual scenarios; a check mark (V) denotes scenarios in which a signal is 
assumed. Where no signaiization is approved, symbol follows name of intersection. 

Bold-face text indicates Level of Service worse than City of San Francisco standard (i.e., LOS E or worse). 

Source: Wilbur Smith Associates 



Effects related to hydrology and to hazardous materials, both of which would be related to the physical 
areas where development would occur, would be similar to impacts of the project because, while 
Alternative B would have a reduced level of concrete production and reduced cargo shipping, compared 
to the project, this alternative would include development on virtually all of the same sites as would the 
project, with the only exception being the Pier 90-94 backlands. With regard to hydrology, therefore. 



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this alternative would result in a reduction of about 38 percent in new stormwater runoff, compared to 
the project (and an increase of 18 percent compared to existing conditions), and the impact would be 
less-than-significant with mitigation, as with the project. 

Concerning hazardous materials, because Alternative B would not include development on the 
Pier 90-94 backlands, there would be no effects related to development on the former landfill at Pier 94. 
As described in the Hazardous Materials setting, however, project effects would be less than significant 
assuming compliance with Regional Water Quality Control Board regulations. Other effects of 
Alternative B with regard to hazardous materials would be less than significant with mitigation, as they 
would with the project. 

Effects on biological resources would be essentially the same as those of the project, and would be less 
than significant, because this alternative, like the project, would include construction of the Illinois Street 
bridge and associated mitigation. 

Because it would result in less substantial traffic impacts than would the project, and would have slightly 
less impact on air quality than would the project, the Reduced Density Alternative would be considered 
the Environmentally Superior Alternative. 

C. ALTERNATIVE C: RESIDENTIAL USE FUTURE SCENARIO 

DESCRIPTION 

With regard to Phase I, this altemative would be the same as the proposed project, in that the six Industry 
Group project components*^ would be implemented, and the Illinois Street Intermodal Bridge would be 
constructed. However, in Phase II, Altemative C would include residential uses at the Pier 70 Mixed- 
Use Opportunity Area, and would also include less office / research and development space there, 
compared to the proposed project. Other future Port development would be the same as with the project. 

At the Pier 70 Mixed-Use Opportunity Area, this altemative would include 500 residential units, 
compared to no residential use under the primary set of cumulative assumptions. Approximately 
200,000 square feet of office / research and development use would be included, compared to 
610,000 square feet of such uses with the project. Retail / commercial activity would be unchanged from 
the project, at 100,000 square feet, and public access / recreational uses would also be unchanged, at 
240,000 square feet. To avoid adverse effects on the future residential uses from continuing operation of 
the working shipyard at Pier 70, the residential units would be located along Illinois Street, while office / 
research and development uses and retail / commercial uses would be between the shipyard and the 
residences, serving as a buffer from shipyard noise. 



The six components would include seven operators; as described in the Project Description, Bode Gravel and Mission Valley 
Rock will be co-tenants. 



Case No. 1999. 377 E 



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VI. ALTERNATIVES 



IMPACTS 

Effects of Alternative C would be generally similar to those of the proposed project. Overall daily 
vehicle trip generation for Phase I and Phase II combined would be about 2.5 percent less than with the 
project, while peak-hour vehicle trips would increase slightly, by about 2.5 percent in the a.m. peak hour 
and almost 6 percent in the p.m. peak-hour. However, the changes, which would total fewer than 
50 additional vehicles in the a.m. peak hour and just over 100 additional vehicles in the p.m. peak hour, 
would not be substantial enough to result in changes in the 2015 level of service at most intersections. 
For those intersections were level of service would be different, most would improve, compared to the 
project, except at Third Street and Cargo Way, where this alternative would result in LOS E in the p.m. 
peak hour, compared to LOS D with the project. Level of service results are shown in Table 25. 

Air quality impacts would be incrementally less substantial than those with the project, owing to the 
slight decrease in daily vehicle trip generation. However, regional effects would be significant, as with 
the project, both on a project- specific and cumulative basis. Like the project, this alternative would not 
result in a project-specific significant effect on local air quality impacts (concentrations of carbon 
monoxide, respirable particulate matter, and diesel particulate). Also like the project, cumulative local 
air quality effects would be unknown, but would be considered significant with this alternative, and the 
contribution would be similar to that of the project. 

Effects related to hydrology and hazardous materials would be virtually unchanged from those of the 
project, because the areas to be developed and the amount of new impervious surface would be the same. 
Because Alternative C would include residential units at the Pier 70 Mixed-Use Opportunity Area, 
remediation of sites where past use of hazardous materials has resulted in contamination would be 
required by law to achieve a higher standard of cleanup. 

Effects on biological resources would be essentially the same as those of the project, and would be less 
than significant, because this alternative, like the project, would include construction of the Illinois Street 
bridge and associated mitigation. 

Depending on the specific configuration of the development at the Pier 70 Mixed-Use Opportunity Area, 
site specific noise analysis, and potentially analysis of nighttime lighting, would be required to determine 
whether 24-hour operations at the Pier 70 shipyard could prove annoying to residents at the Mixed-Use 
Opportunity Area. 



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VI. ALTERNATIVES 



TABLE 25 

TRAFFIC LEVELS OF SERVICE FOR ALTERNATIVE C 



A.M. Peak Hour 
2015 + Alternative C 

Project (2015) 
LOS Delay LOS Delay 



P.M. Peak Hour 
2015 + Alternative C 
Project (2015) 
LOS Delay LOS Delay 



Intersection 

1-280 SB on-ramp/ Mariposa Street 
1-280 NB off-ramp/ Mariposa Street 
Minnesota / Mariposa Streets 
Third / Mariposa Streets 
Illinois / Mariposa Streets 
Third / 20th Streets 
Illinois / 20th Streets 
Third / 25th Streets 

Mitigated Level of Service (2015) 
Illinois / 25th Streets t 

Mitigated Level of Service (2015) 
Pennsylvania / 1-280 SB on-ramp t 

.Mitigated Level of Service (2015) 
Evans Av. / Cesar Chavez St. 
Pennsylvania / Cesar Chavez Streets 

Mitigated Level of Service (2015) 
Third / Cesar Chavez Streets 

Mitigated Level of Service (2015) 
Illinois / Cesar Chavez Streets t 

Mitigated Level of Service (2015) 
Third Street / Cargo Way 

Mitigated Level of Service (2015) 
Amador Street / Cargo Way t 

Mitigated Level of Service (2015) 
Third Street / Evans Avenue 



1 


>60 


FV 


>60 


F 


>60 


fV 


>60 


B V 


13.9 


B 


14.2 


E 


59.1 


E 


44.9 


D 


25.1 


D 


23.5 


D 


37.5 


C 


14.8 


C 


17.3 


D 


27.3 


D 


28.6 


D 


27.3 


N/A 


N/A 


N/A 


N/A 


B(C) 


9.3 


B(C) 


7.3 


N/A 


N/A 


N/A 


N/A 


B(C) 


5.3 


A(B) 


5.1 


N/A 


N/A 


N/A 


N/A 


F 


>60 


F 


>60 


F 


>60 


F 


>60 


D 


26.7 


D 




F 


>60 


F 


>60 


D 




D 




F 


>60 


F 


>60 


D 


32.6 


D 




C 


18.7 


C 


17.8 


N/A 


N/A 


N/A 


N/A 


F 


>60 


F 


>60 


C 


75.7 


C 




D 


37.3 


D 


31.3 



E V 


46.2 


D 


36.6 


E 


42.1 


E 


40.2 


cV 


15.9 


C 


16.0 


E 


56.4 


E 


48.6 


D 


21.5 


C 


16.9 


D 


37.2 


C 


22.0 


C 


11.0 


B 


8.8 


F 


>60 


F 


>60 


D 


34.1 


D 




F 


>60 


B(C) 


8.6 


A 


4.3 


N/A 


N/A 


E(F) 


40.9 


D 


34.3 


B 


8.5 


N/A 


N/A 


D 


36.9 


D 


27.6 


F 


>60 


F 


>60 


D 


32.6 


D 


<32.6 


F 


>60 


F 


>60 


D 




D 




F 


>60 


F 


>60 


B 


11.5 


B 




D 


38.9 


E 


40.6 


N/A 


N/A 


D 




F 


>60 


E(F) 


46.6 


B 


14.4 


N/A 


N/A 


D 


34.4 


D 


33.8 



KEY: LOS = Level of Service; Delay = Delay in average seconds per vehicle. Where delay is in excess of 60 seconds, the 
notation ">60" is used; beyond 60 seconds, measurement of average delay becomes unreliable. 

+ - Unsignaiized intersection. LOS and delay reported for overall intersection; LOS in parentheses is for critical movement 

(normally, minor street left-turn), when worse than overall LOS. Where previously approved signalization is to occur in the 
future, "+" symbol is used with LOS for individual scenarios; a check mark (V) denotes scenarios in which a signal is 
assumed. Where no signalization is approved, symbol follows name of intersection. 

Bold-face text indicates Level of Service worse than City of San Francisco standard (i.e., LOS E or worse). 

SOURCE: Wilbur Smith Associates 



Case No. 1 999. 3 77 E 



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CHAPTER VII 



DEIR DISTRIBUTION LIST 



LIST OF THOSE TO RECEIVE MAILED COPIES OF DRAFT EIR 



FEDERAL AND STATE 
AGENCIES 

Calvin Fong, Chief, Regulatory Branch 

U.S. Army Corps of Engineers 

333 Market Street 

San Francisco, CA 94105 

Dave Sulouff, Chief, Bridge Section 
U.S. Coast Guard 
Building 50-6 
Coast Guard Island 
Alameda, CA 94501-5100 

Roslyn Johnson 
U.S. EPA -Region IX 
75 Hawthorne Street 
San Francisco, CA 94105 

Governor's Ofc. of Plan' g & Research 
State Clearinghouse 
1400 Tenth Street 
Sacramento, CA 95814 

David Plummer, Public Land Manager 
State Lands Commission 
100 Howe Avenue #100 South 
Sacramento, CA 95825-8202 

Ray Evans 

California Public Utilities Commission 
505 Van Ness Avenue 
San Francisco, C A 94102 

R. Rempel, Environmental Svcs. Div. 
Department of Fish & Game 
1416 Ninth Street 
Sacramento, CA 94244-2090 



State Office of Historic Preservation 
P.O. Box 942896 
Sacramento, CA 94296-0001 
Attn.: Carol Roland 

Northwest Information Center 
California Archaeological Inventory 
Department of Anthropology 
Sonoma State University 
Rohnert Park, CA 94928 
Attn: Leigh Jordan 

California Department of Transportation 
Ofc. of Transportation Planning - B 
P.O. Box 23660 
Oakland, CA 94623-0660 
Attn : Nandini Shridhar 

Suzie Betzler 

Department of Boating & Waterways 
1629 S Street 
Sacramento, CA 95814 

REGIONAL AGENCIES 

Association of Bay Area Governments 
P.O. Box 2050 
Oakland, CA 94604-2050 
Attn: Suzan Ryder 

Association of Bay Area Governments 
101 8th Street 
Oakland, CA 94607 
Attn: Jean Pedersen 

Regional Water Quality Control Board 
San Francisco Bay Region 
1515 Clay St., Suite 1400 
Oakland, C A 94612 
Attn: Judy Huang 



Metropolitan Transp. Commission 
101 8th Street 
Oakland, CA 94607 
Attn: Craig Goldblatt 

Steve McAdam 

Bay Conservation and Devel. Comm. 
50 California Street, Suite 2600 
San Francisco, CA 941 1 1 

Bay Area Air Quality Mgmt. District 

939 Ellis Street 

San Francisco, CA 94109 

Attn: Joseph Steinberger 

Kenneth Scheidig 
General Counsel's Office 
AC Transit 
1600 Franklin Street 
Oakland, C A 94612 

BART 

Planning Division 
800 Madison Street 
Oakland, CA 94607 

CITY AND COUNTY OF 
SAN FRANCISCO 

Sue Olive 

Muni Third Street Light Rail Project 

1145 Market Street 

San Francisco, CA 94102 

Department of Building Inspection 
1660 Mission Street 
San Francisco. C A 94103 
Attn: Frank Chiu, Director 

Mayor's Office of Community Devel. 
25 Van Ness Ave., Suite 700 
San Francisco. Ca 94102 



Case No. I999.377E 



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VII. DISTRIBUTION LIST 



Landmarks Preservation Advisory Bd. 

1660 Mission Street 

San Francisco, CA 94103 

Attn: Andrea Green, Secretary 

Daniel Reidy, President 

Penney Magrane, Vice President 

Ina Dearman 

Paul Finwall 

Nancy Ho-Belli 

Tim Kelley 

Jeremy Kotas 

Donna Levitt 

Suheil Shatara 

Marcia Rosen, Director 
Mayor's Office of Housing 
25 Van Ness Avenue, Suite 600 
San Francisco, CA 94102 

Maria Ayerdi 

Mayor Office of Economic Devel. 
City Hall, Room 448 
San Francisco, CA 94102 

Bureau of Energy Conservation 
Hetch Hetchy Water & Power 
1 155 Market Street, 4 Floor 
San Francisco, C A 94103 
Attn: John Deakin, Director 

Public Utilities Commission 

1 155 Market Street 

San Francisco, CA 94102 

Attn: Anson B. Moran, General Mgr. 

Recreation & Park Department 
McLaren Lodge, Golden Gate Park 
Fell and Stanyan Streets 
San Francisco, CA 941 17 
Attn: Deborah Learner 

Police Department 
Planning Division, Hall of Justice 
850 Bryant Street, Room 500 
San Francisco, CA 94103 
Attn: Capt. Timothy Hettrich 

San Francisco Public Utilities Comm. 
425 Mason Street, 4 Roor 
San Francisco, CA 94102 
Attn : Bruce Bemhard 

San Francisco Dep't. of Public Works 
Bureau of Street Use and Mapping 
875 Stevenson Street, Room 465 
San Francisco, CA 94103 
Attn.: Barbara Moy 



San Francisco Planning Commission 

1660 Mission Street 

San Francisco, CA 94103 

Attn: Linda Avery, Secretary 

Anita Theoharis, President 

Beverly Mills, Vice President 

Roslyn Baltimore 

Hector Chinchilla 

William Fay 

Cynthia Joe 

Jim Salinas, Jr. 

San Francisco Dep't. of Pkg. & Traffic 
Traffic Engineering Division 
25 Van Ness Avenue 
San Francisco, CA 94102 
Attn: Bond Yee 

San Francisco Fire Department 

Division of Planning & Research 

698 Second Street 

San Francisco, C A 94107 

Attn: Lorrie Kalos, Asst. Deputy Chief 

San Francisco Municipal Railway 
MUNI Planning Division 
949 Presidio Avenue, Room 204 
San Francisco, CA 941 15 
Attn: Peter Straus 

Anthony Delucchi 

San Francisco Real Estate Department 
25 Van Ness Avenue, Suite 400 
San Francisco, CA 94102 

"Water Department 
Distribution Division 
1990 Newcomb Avenue 
San Francisco, CA 94124 
Attn: Joe Pelayo, Sr. Engineer 

San Francisco Dep't. of Public Works 
Bureau of Engineering 
1680 Mission Street 
San Francisco, C A 94103 
Attn.: Nelson Wong 

Jose Campos 

San Francisco Redevelopment Agency 
770 Golden Gate Avenue 
San Francisco, CA 94102 



LIBRARIES 

Document Library (Three Copies) 
City Library - Civic Center 
San Francisco, CA 94102 
Attn: Kate Wingerson 

Stanford University Libraries 
Jonsson Library of Government 

Documents 
State & Local Documents Division 
Stanford, CA 94305 

Government Publications Department 
San Francisco State University 
1630 Holloway Avenue 
San Francisco, CA 94132 

Hastings College of the Law - Library 

200 McAllister Street 

San Francisco, CA 94102-4978 

Institute of Government Studies 
109 Moses Hall 
University of California 
Berkeley, CA 94720 

MEDIA 

San Francisco Chronicle 

925 Mission Street , 

San Francisco, CA 94103 

Attn: San Francisco Desk 

San Francisco Examiner 
P.O. Box 7260 
San Francisco, CA 94120 
Attn: Gerald Adams 

San Francisco Bay Guardian 
520 Hampshire Street 
San Francisco, CA 941 10 
Attn: Gabe Roth, City Editor 

SF Weekly 

185 Berry Street, Suite 3800 
San Francisco, C A 94107 

San Francisco Independent 
1201 Evans Avenue 
San Francisco, CA 94124 
Attn.: City Desk 

The Sun Reporter 

1791 Bancroft Avenue 

San Francisco, CA 94124-2644 



Case No. 1 999. 3 77 E 



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Vn. DISTRIBUTION LIST 



San Francisco Business Times 
275 Battery Street, Suite 940 
San Francisco, CA 941 1 1 
Attn: Tim Turner 

Tenderloin Times 
146 Leavenworth Street 
San Francisco, CA 94102 
Attn: Rob Waters 

Associated Press 
1390 Market Street, Suite 318 
San Francisco, CA 94102 
Attn: BillShiffman 

Leland S. Meyerzone 

KPOO - FM 

P.O. Box 6149 

San Francisco, C A 94101 

GROUPS & INDIVIDUALS 

Albert Beck 
Eco/Plan International 
3028 Esplanade Street, Suite A 
Chico, CA 95973-4924 

Chas. E. Chase, Exec. Director 
San Francisco Architectural Heritage 
2007 Franklin Street 
San Francisco, C A 94103 

Greenwood Press, Inc. 
P.O. Box 5007 
Westport, Conn 06881-9900 
Attn: Eric LeStrange 

Alice Suet Yee Barkley, Esq. 
30 Blackstone Court 
San Francisco, CA 94123 

Sue C. Hester 

Attomey-at-Law 

870 Market Street, Room 1 128 

San Francisco, CA 94102 

Reuben & Alter 

235 Pine Street, 16 Floor 

San Francisco, CA 94104 

S.F. Planning & Urban Research Ass'n. 

312 Sutter Street 

San Francisco, CA 94108 

Attn.: James Chappell, Exec. Director 

San Francisco Beautiful 

41 Sutter Street, Suite 709 

San Francisco, CA 94104 

Attn: Dee Dee Workman, Exec. Dir. 



San Francisco Tomorrow 
41 Sutter Street, Suite 1579 
San Francisco, CA 94104-4903 
Attn: Tony Kilroy 

Joel Ventresca 

1278 44th Avenue 

San Francisco, CA 94122 

San Francisco BayKeeper 

Building A 

Fort Mason Center 

San Francisco, CA 94123 

David Lewis 

Save San Francisco Bay Assn. 
1736 Franklin Street, Fourth Floor 
San Francisco, CA 94612 

Jeff Manner 

Coalition for Better Wastewater Sol'ns. 

260 Ripley Street 

San Francisco, CA 94110 

Sandra Trelfall 
Public Trust Group 
P.O. Box 11520 
Oakland, CA 94611-0520 

ARC Ecology 

833 Market Street 

San Francisco, CA 94103 

Ruth Gravanis 

Golden Gate Audubon Society 
2530 San Pablo Avenue, Suite G 
Berkeley, CA 94702 

Sierra Club 

85 Second Street, Second Floor 
San Francisco, CA 94105-3441 

San Francisco Chamber of Conunerce 
465 California Street 
San Francisco, CA 94104 

Niko Letunic 

San Francisco Bay Trail 

Ass'n. of Bay Area Governments 

P.O. Box 2050 

Oakland, CA 94604 

Mike Thomas 

Communities for a Better Environment 
500 Howard Street. Suite 506 
San Francisco, CA 94105 



Nan Roth 

1436 Kearny Street 

San Francisco, CA 94133 

Doug Gardner 

Catellus Development Corp. 

255 Channel Street 

San Francisco, CA 94107 

Janet Carpinelli 
934 Minnesota Street 
San Francisco, CA 94107 

Sophenia Maxwell 
1568 Jerrold Avenue 
San Francisco, CA 94124 

Ollis Burgess 

1773 Oakland Avenue 

San Francisco, CA 94124 

Gerald Taylor 

Bayview Sand 

51 12 Third Street 

San Francisco, CA 94124 

Alfred Williams 

Alfred Williams Consultancy 

P.O. Box 591180 

San Francisco, CA 94159-1 180 

Karen Pierce 

Health & Envir. Assess. Project 
Southeast Health Center 
2401 Keith Street 
San Francisco, C A 94124 

Corinne Woods 
Bayview Boat Club 
300 Channel Street, Box 10 
San Francisco, C A 94107 

Sandra Peterson 
Potrero Neighborhood Boosters 
347 Pennsylvania Street 
San Francisco. C A 94107 

Roger Peters 

Amador Street Tenants Assn. 
1655 Chestnut Street #204 
San Francisco. C A 94123 

Julia Viera 

Friends of Isiais Creek 

6 Hiliview Court 

San Francisco, C A 94124 



Case No. 1999.377E 



111 

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VII. DISTRIBUTION LIST 



Jerry Bridges 
Marine Terminals Corp. 
5190 Seventh Street 
Oakland, CA 94607 

Anne Eng, Staff Attorney 
Golden Gate Univ. Law School 
Environmental Law & Justice Clinic 
536 Mission Street 
San Francisco, CA 94105 

Jane Morrison 

44 Woodland Street 

San Francisco, CA 941 17 

Mohammed Nuru 
SLUG 

2088 Oakdale Avenue 
San Francisco, CA 94124 

Linda Richardson 
SAEJ 

198 Jerrold Avenue 

San Francisco, CA 94124 

David Gavrich 

ECDC Environmental 

Pier 96 Railyard 

669 Amador Street 

San Francisco, C A 94124 

Bobby Guillory 
Local 10 

400 North Point Street 
San Francisco, CA 94133 

Claude Wilson 
SAEJ 

120 Jerrold Avenue 

San Francisco, CA 94124 

Jennifer Clary 

795 25th Avenue #3 

San Francisco, CA 94121 



During Associates 

120 Montgomery Street, Suite 2290 

San Francisco, C A 94104 

EIP Associates 

601 Montgomery Street, Suite 500 
San Francisco, CA 94 11 1 

Environmental Science Associates 

225 Bush St., Suite 1700 

San Francisco, CA 94104-4207 

Nichols-Berman 
142 Minna Street 
San Francisco, CA 94105 
Attn: Louise Nichols 

Sally Maxwell 
Maxwell & Associates 
1522 Grand View Drive 
Berkeley, CA 94705 

Ron Foster 

Wilbur Smith Associates 

1 145 Market Street, 10 Floor 

San Francisco, C A 94103 

Chi-Hsin Shao 
CHS Consulting Group 
153 Kearny Street, Suite 209 
San Francisco, C A 94108 

Korve Engineering 

1 16 New Montgomery St., Ste. 531 

San Francisco, CA 94105 

Steve Vettel 

Morrison & Foerster 

425 Market Street, 

San Francisco, CA 94105-2482 



Bob Cox 

Hanson Aggregates 
4501 Tidewater Avenue 
Oakland, CA 94601 

Beesian Yip 

Cooper White and Cooper 

201 California Street, Suite 1700 

San Francisco, CA 941 1 1 



Pier 70 Advisory Group 
Joe P. Boss 
Jennifer Clary 
Meb Gordon 
Dwayne Jones 
Greg Markelus 
Paul Nixon 
Stan Smith 
Corinne Woods 
Shelley Bell 
Mara Brazer 
Tom Escher 
D. Carl Hanson 
John Killacky 
John Moran 
Mohammed Nuru 
Steven L. Vettel 
John Borg 
Charles E. Chase 
Susan Eslick 
Dennis Herrera 
Toby Levine 
Toye Moses 
Paul Sherrill 
Julia Viera 



Case No. 1999. 377 E 



178 

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Southern Waterfront SEIR 



VII. DISTRIBUTION LIST 



LIST OF THOSE TO RECEIVE MAILED NOTICES OF AVAILABILITY 



GROUPS & INDIVIDUALS 

AIA - San Francisco Chapter 
130 Sutter Street 
San Francisco, CA 94104 
Attn: Bob Jacobvitz 

Richard Mayer 
Artists Equity Assn. 
27 Fifth Avenue 
San Francisco, CA 94118 

John Bardis 

Sunset Action Committee 
1501 Lincoln Way, #503 
San Francisco, CA 94122 

Bruce White 

3207 Shelter Cove Avenue 
Davis, CA 95616 

Bay Area Council 

200 Pine Street, Suite 300 

San Francisco, CA 94104-2702 

Michael Dyett 

Dyett & Bhatia 

70 Zoe Street 

San Francisco, CA 94103 



Nancy Taylor 
Baker & McKenzie 
Two Embarcadero Center, 25 
San Francisco, CA 941 1 1 



th 



Floor 



Peter Bosselman 

Environmental Simulation Laboratory 
119 Wurster Hall 
University of California 
Berkeley, CA 94720 

San Franciscans for Reasonable Growth 

243 Bartlett Street 

San Francisco, CA 941 10 

Attn: David Jones 

Brobeck, Phleger, Harrison 
One Market Plaza 
San Francisco, Ca 94105 
Attn: Susan R. Diamond 

David Cincotta 

1388 Sutter Street, Suite 900 

San Francisco, Ca 94102 



Cahill Contractors, Inc. 
425 California Street, Suite 2300 
San Francisco, CA 94104 
Attn: Jay Cahill 

Chinatown Resource Center 
1525 Grant Avenue 
San Francisco, CA 94133 



,th. 



Chicago Title 

388 Market Street, 13"' Floor 
San Francisco, CA 941 1 1 
Attn: Carol Lester 

Chickering & Gregory 
615 Battery Street, 6 Floor 
San Francisco, CA 941 11 
Attn: Ken Soule 

Coalition for San Francisco 

Neighborhoods 
P.O. Box 42-5882 
San Francisco, CA 94142 - 5882 

Coldwell Banker-Finance Department 

1699 Van Ness Avenue 

San Francisco, CA 94109 

Attn: Doug Longyear, Tony Blaczek 

Cushman & Wakefield of Califomia 

Bank of America Center 

555 Califomia Street, Suite 2700 

San Francisco, CA 94104 

Attn: W. Stiefvater, L. Farrell 

Damon Raike & Co. 
100 Pine Street, Suite 1800 
San Francisco, CA 941 1 1 
Attn: Frank Fudem 

Verba Buena Consortium 
109 Minna Street, Ste. 575 
San Francisco, CA 94105 
Attn: John Elberling 

Downtown Association 
5 Third Street, Suite 520 
San Francisco, CA 94103 
Attn: Carolyn Dee 

Farella, Braun & Martel 
235 Montgomery Street 
San Francisco, CA 94104 
Attn: Mary Murphy 



Larry Mansbach 

44 Montgomery Street 

San Francisco, CA 94104 

Philip Fukuda 

TRl Commercial 

1 Califomia Street, Suite 1200 

San Francisco, CA 941 1 1 

Gensler and Associates 
550 Keamy Street 
San Francisco, CA 94103 
Attn: Peter Gordon 

Gladstone & Associates 
177 Post Street, Penthouse 
San Francisco, CA 94108 
Attn: Brett Gladstone 

Goldfarb & Lipman 
One Montgomery Street 
West Tower, 23 Floor 
San Francisco, CA 94104 
Attn: Paula Crow 

Gruen, Gmen & Associates 

564 Howard Street 

San Francisco, CA 94105 

Jim Haas 
Civic Pride 

World Trade Center, Room 289 
San Francisco, CA 94 1 1 1 

Valerie Hersey 
Munsell Brown 
950 Battery 

San Francisco, CA 941 1 1 

The Jefferson Company 

10 Lombard Street, Third Floor 

San Francisco, C A 941 18 

Jones Lang Wootton 
710 One Embarcadero Center 
San Francisco. CA 941 1 1 
Attn: Sheryl Bratton 

Kaplan/McLaughlin/Diaz 
222 Vallejo Street 
San Francisco, CA 941 1 1 
Attn: Jan Vargo 



Case No. 1999.377E 



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VII. DISTRIBUTION LIST 



Legal Assistance to the Elderly 
Brent Kato 

1453 Mission Street, 5 Floor 
San Francisco, C A 94103 

Milton Meyer & Co. 
One California Street 
San Francisco, CA 94 111 
Attn: James C. DeVoy 

Cliff Miller 

970 Chestnut Street, #3 
San Francisco, CA 94109 

Robert Meyers Associates 

120 Montgomery Street, Suite 2290 

San Francisco, CA 94104 

Morrison & Foerster 

425 Market Street 

San Francisco, CA 94105-2482 

Attn: Jacob Herber 

National Lawyers Guild 
558 Capp Street 
San Francisco, CA 94110 
Attn: Regina Sneed 

Pacific Exchange 

301 Pine Street 

San Francisco, CA 94104 

Attn: Dale Carleson 

Page & Tumbull 

724 Pine Street 

San Francisco, CA 94109 

Patri-Merker Architects 
400 Second Street, Suite 400 
San Francisco, CA 94107 
Attn: Marie Zeller 

Pillsbury, Madison & Sutro 
P.O. Box 7880 
San Francisco, CA 94120 
Attn: Marilyn L. Siems 



Dennis Purcell 

Coblentz, Patch, Dufl^ & Bass 
222 Kearny Street, 7 Floor 
San Francisco, Ca 94108 

Ramsay/Bass Interest 
3756 Grant Avenue, Suite 301 
Oakland, CA 94610 
Attn: Peter Bass 

David P. Rhoades & Associates 

364 Bush Street 

San Francisco, CA 94104-2805 

Herb Lembcke, FAIA 
Rockefeller & Assoc. Realty L.P. 
Four Embarcadero, Suite 2600 
San Francisco, CA 94 11 1-5994 

Rothschild & Associates 
244 California Street, Suite 500 
San Francisco, CA 941 1 1 
Attn: Thomas N. Foster 

S.F. Bldg. & Constr. Trades Council 
2660 Newhall Street, #116 
San Francisco, CA 94124-2527 
Attn: Stanley Smith 

San Francisco Conv. & Visitors Bureau 

201 - Third Street, Suite 900 

San Francisco, CA 94103 

Attn: John Marks, Exec. Director 

San Francisco Labor Council 
1 188 Franklin Street, #203 
San Francisco, CA 94109 
Attn: Walter Johnson 

John Sanger, Esq. 

1 Embarcadero Center, 12th Floor 

San Francisco, CA 941 1 1 

Sedway Group 

3 Embarcadero Center, Suite 1 1 50 
San Francisco, CA 941 1 1 



Solem & Associates 
550 Kearny Street 
San Francisco, CA 94108 
Attn: Jim Ross 

Square One Film & Video 

725 Filbert Street 

San Francisco, CA 94133 

Steefel, Levitt & Weiss 
199 -First Street 
San Francisco, CA 94105 
Attn: Robert S. Tandler 

Sustainable San Francisco 

P.O. Box 460236 

San Francisco, CA 94146 

Tenants & Owners Development Corp. 

230 - Fourth Street 

San Francisco, C A 94103 

Attn: John Elberling 

Jerry Tone 

Montgomery Capital Corp. 

244 California St. 

San Francisco, CA 941 11 

UCSF Capital Planning Department 

145 Irving Street 

San Francisco, CA 94122 

Attn: Bob Rhine 

Jon Twichell Associates 
70 Hermosa Ave. 
Oakland, CA 94618 

Stephen Weicker 
899 Pine Street, #1610 
San Francisco, CA 94108 

Calvin Welch 

Council of Community Housing Orgs. 

409 Clayton Street 

San Francisco, CA 941 17 

Feldman, Waldman & Kliijje 
3 Embarcadero Center, 28 Floor 
San Francisco, CA 941 1 1 
Attn: Howard Wexler 

Eunice Wiliette 
1323 Oilman Avenue 
San Francisco, CA 94124 

Bethea Wilson & Associates 
Art In Architecture 
2028 Scott, Suite 204 
San Francisco, CA 941 15 



Planning Analysis & Development 
50 Francisco Street 
San Francisco, CA 94133 
Attn: Gloria Root 

Mrs. G. Bland Piatt 
362 Ewing Terrace 
San Francisco, CA 941 18 



Shartsis Freise & Ginsbijrg 
One Maritime Plaza, 18 Floor 
San Francisco, CA 941 1 1 
Attn: Dave Kremer 

Skidmore, Owings & Merrill 
333 Bush Street 
San Francisco, CA 94104 
Attn: John Kriken 



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CHAPTER VIII 



SUMMARY OF COMMENTS AND RESPONSES 



TABLE OF CONTENTS 



A. INTRODUCTION 

B. LIST OF PERSONS COMMENTING 

C. WRITTEN COMMENTS AND RESPONSES 

A. Calvin C. Fong, U.S. Army Corps of Engineers 

B. Harry Y. Yahata, California Department of Transportation 

C. Dan Boardman, Bode Gravel Company 

D. William Howard, Mission Valley Rock Company 

E. Lawrence W. Appleton, Hanson Aggregates Mid-Pacific Inc. 

F. H. W. Reppert, KMC Pacific Materials 

G. Jack Isola, Waste Resources Technologies 

H. Alex Lantsberg and Jennifer Clary, Alliance for a Clean Waterfront 

I. Jeff Marmer, Coalition for Better Wastewater Solutions 
J. Janet Carpinelli, Dogpatch Neighborhood Association 

K. Anne Eng and Lynne Saxton, Environmental Law and Justice Clinic, 

Golden Gate University Law School 
L. Robin Chiang, Friends of Islais Creek 

M. Arthur Feinstein, Executive Director, Golden Gate Audubon Society 

N. Toby Levine and John Borg, Pier 70 Advisory Group 

O. Carl Hanson, San Francisco Drydock, Inc. 

P. Jane Morrison and Jennifer Clary, San Francisco Tomorrow 

Q. Ruth Gravanis 

R. Corrine W. Woods 

S. California Regional Water Quality Control Board 

D. PUBLIC HEARING COMMENTS AND RESPONSES 

E. STAFF-INITIATED TEXT CHANGES 



Page 
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LIST OF FIGURES 

2. Project Components (Revised) 
7. Sensitive Receptors (Revised) 



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VIII. SUMMARY OF COMMENTS AND RESPONSES 



SECTION A 

INTRODUCTION 

This document contains public comments received on the Draft Supplemental Environmental Impact 
Report (Draft SEIR, or DSEIR) prepared for the proposed Southern Waterfront Project, and responses to 
those comments. Also included in this document are staff-initiated text changes. 

Following this introduction. Section B contains a list of all persons and organizations who submitted 
written comments on the Draft SEIR and who testified at the public hearing on the Draft SEIR held on 
October 26, 2000. 

Sections C and D contain the comments and responses. Comments are grouped by commenter to allow 
commenters to easily find the responses to their comment(s). As the subject matter of one comment may 
overlap that of others, the reader may be referred to a prior response. 

Section C contains comment letters received during the public review period from September 23 to 
November 7, 2000, and the responses to each comment. Each substantive comment on the SEIR is 
labeled with a number in the margin and the response to each comment is presented immediately after 
the letter containing that comment. 

Section D contains transcribed comments made at the public hearing on the Draft SEIR and the 
responses to each of those comments. Each substantive comment on the SEIR is similarly labeled with a 
number in the margin, and the responses to each set of comments follow those comments. 

Some comments do not pertain to physical environmental issues, but responses are included to provide 
additional information for use by decision makers. 

Section E contains text changes to the Draft SEIR made by the SEIR preparers subsequent to publication 
of the Draft EIR to correct or clarify information presented in the DSEIR. 

These comments and responses will be incorporated into the Final SEIR as a new chapter. Text changes 
resulting from comments and responses will also be incorporated in the Final SEIR, as indicated in the 
responses. 



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VIII. SUMMARY OF COMMENTS AND RESPONSES 



SECTION B 

LIST OF PERSONS COMMENTING 

Written Comments 

Federal Agency 

Calvin C. Fong, Chief, Regulatory Branch, San Francisco District, U.S. Army Corps of Engineers, letter, 
October 20, 2000 

State Agency 

Harry Y. Yahata, District Director, California Department of Transportation, letter, October 25, 2000 

Susan Gladstone, Environmental Specialist IV, California Regional Water Quality Control Board, letter, 
December 29, 2000' 

Companies. Organizations, and Individuals 
Industry Group (Project Co-Sponsors) 

Dan Boardman, President, Bode Gravel Company, letter, November 3, 2000 

William Howard, Vice President, Mission Valley Rock Company, letter, November 3, 2000 

Lawrence W. Appleton, Manager of Engineering and Environmental Affairs, Hanson Aggregates 
Mid-Pacific Inc., letter, November 6, 2000 

H. W. Reppert, Director of Environmental Affairs, RMC Pacific Materials, letter, November 1, 2000 

Jack Isola, General Manager, Waste Resources Technologies, letter, November 7, 2000 

Others 

Alex Lantsberg, Sewage and Stormwater Committee Co-Chair, and Jennifer Clary, Port Chair, Alliance 
for a Clean Waterfront, letter, November 10, 2000 

Jeff Marmer, Coalition for Better Wastewater Solutions / Alliance for a Clean Waterfront, letter, 
November 10, 2000 

' Note that this letter was dated and received by the Planning Department several weeks after the close of the public comment 
period, and shortly before publication of the Summary of Comments and Responses. This letter therefore appears at the end 
of Section C of this document. 



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Vni. SUMMARY OF COMMENTS AND RESPONSES 

B. LIST OF PERSONS COMMENTING 

Janet Carpinelli, Corresponding Secretary, Dogpatch Neighborhood Association, letter, November 1, 
2000 

Anne Eng and Lynne Saxton, Environmental Law and Justice Clinic, Golden Gate University Law 
School, letter, November 7, 2000 

Robin Chiang, President, Friends of Islais Creek, undated letter (received November 8, 2000) 

Arthur Feinstein, Executive Director, Golden Gate Audubon Society, letter, November 7, 2000 

Toby Levine and John Borg, co-chairs. Pier 70 Advisory Group, letter, October 25, 2000 

Carl Hanson, President and General Manager, San Francisco Drydock, Inc., letter, November 7, 2000 

Jane Morrison, President, and Jennifer Clary, Waterfront Chair, San Francisco Tomorrow, letter, 
November 10, 2000 

Ruth Gravanis, letter, November 9, 2000 

Conine W. Woods, letter, November 7, 2000 

Public Hearing Comments, October 26, 2000 

Toby Levine, co-chair. Pier 70 Advisory Board 

Alex Lantsberg 
Juan Barragan 
Patrick Maury Rump 
Dana Lanza 

Lynne Saxton, Environmental Law and Justice Clinic 

Roslyn Baltimore, member, San Francisco Planning Commission 



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VIII. SUMMARY OF COMMENTS AND RESPONSES 



SECTION C 

WRITTEN COMMENTS AND RESPONSES 



This chapter includes copies of the comment letters received during the public review period on the Draft 
SEIR and responses to those comments. Each substantive comment on the Draft SEIR is labeled with a 
number in the margin and the response to each comment is presented immediately after the letter 
containing that connment. Where responses have resulted in changes to the text of the Draft SEIR, these 
changes will also appear in the Final SEIR. 



97.470E 



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475 Brannan Slrcel EIR 




DEPARTMENT OF THE ARMY 



SAN FRANCISCO DISTRICT, CORPS OF ENGINEERS 
333 MARKET STREET 
SAN FRANCISCO, CALIFORNIA 94105-2197 




REPLY TO 



Regulatory Branch 



SUBJECT: File Number 25665S 



Ms. Hillary Giteknan 
City and County of San Francisco 
Environmental Review Officer 
1660 Mission Street, Suite 500 
San Francisco, California 94103 



Dear Ms. Gitelman: 

Your request for comments on the Draft Supplemental Envirormiental Impact Report 
concerning the San Francisco Southem Waterfront, dated September 23, 2000, was received on 
October 3, 2000. The proposed project includes the expansion of private industry, capital 
improvements and potential fiiture development at the Southem Waterfront, a port within the San 
Francisco Bay and in the City and County of San Francisco, California. While the majority of 
your proposed project does not impact jurisdictional waters of the U.S., the proposed Illinois 
Street Intermodal Bridge may impact portions of Islais Creek and might therefore be subject to 
Corps regulatory authority. 

All proposed work and/or structures extending bayward or seaward of the line on shore 
reached by: (1) mean high water (MHW) in tidal waters, or (2) ordinary high water in non-tidal 
waters designated as navigable waters of the United States, must be authorized by the Corps of 
Engineers pursuant to Section 10 of the Rivers and Harbors Act of 1899 (33 U.S.C. 403). 
Additionally, all work and structures proposed in unfilled portions of the interior of diked areas 
below former MHW must be authorized under Section 10 of the same statute. 

In addition, all proposed discharges of dredged or fill material into waters of the United 
States must be authorized by the Corps of Engineers pursuant to Section 404 of the Clean Water 
Act (CWA) (33 U.S.C. 1344). Waters of the United States generally mclude tidal waters, lakes, 
ponds, rivers, streams (including intermittent streams), and wetlands. 

Your proposed work appears to be within our jurisdiction and a permit may be required. 
Application for Corps authorization should be made to this office using the application form in 
the enclosed pamphlet. To avoid delays it is essential that you enter the file number at the top of 
this letter into Item No. 1 . The application must include plans showing the location, extent and 
character of the proposed activity, prepared in accordance with the requirements contained in this 
pamphlet. You should note, in planning your work, that upon receipt of a properly completed 
application and plans, it may be necessary to advertise the proposed work by issuing a public 



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notice for a period of 30 days. 



2 



If an individual peraiit is required, it will be necessary for you to demonstrate to the 
Corps that your proposed fill is necessary because there are no practicable alternatives, as 
outlined in the U.S. Environmental Protection Agency's Section 404(b)(1) Guidelines. A copy is 
enclosed to aid you in preparation of this alternative analysis. 

If you have any questions, please call Phelicia Gomes of our Regulatory Branch at 415- 
977-8452. Please address correspondence to Regulatory Branch and refer to the file number at 
the head of this letter. 



Sincerely, 




^ Calvin C.Fong 

Chief, Regulatory Branch 



Enclosures 



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VIII. SUMMARY OF COMMENTS AND RESPONSES 

C. WRITTEN COMMENTS AND RESPONSES 

LETTER A - U.S. ARMY CORPS OF ENGINEERS 

A-1) The comment is noted. The SEIR notes, in the Project Description on p. 22 and in the discussion 
of Land Use, Plans, and Policies on p. 41, that approval of the proposed Illinois Street Intermodal 
Bridge would require approval by the U.S. Army Corps of Engineers. The Port of San Francisco 
or its designee would need to obtain all necessary permits for the proposed bridge prior to the 
initiation of bridge construction. 



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« 



pATF OF CALIFORNIA • BUSIN FSS. TRANSPORTATION AND HOUSING AGENCY 



GRAY DAVIS Onvomor 



DEPARTMENT OF TRANSPORTATION 




P O BOX 23660 
OAKLAND, OA 94623-0660 



Tel; (510) 286-4444 
Fax (510) 286-5513 
TDD (S10) 286-4454 



October 25, 2000 



SM-280-5.62 

94123007 

SM280110 



(D 



Ms. Lezley Buford 
San Francisco Planning Department 
1660 Mission Street, Suite 500 
San Francisco, CA 94103 

Dear Ms. Buford: 

Supplemental Environmental Impact Report (SEIR) for the San Francisco Southern 
Waterfront Project; City and County of San Francisco 

Thank you for including the California Department of Transportation (Caltrans) in the 
environmental review process for the above referenced project. We have examined the 
SEIR and have the following comments: 

1. The traffic data in the SEIR is insufficient to evaluate the impact of the proposed 
project on State Highways from an operational point of view, especially at the 
Mariposa Street /Interstate 280 interchange southbound and northbound on-and-off 
ramps. 

2. Please submit a copy of the project plans, specifications and estimates (PS&E) when 



If you need further information or have any questions regarding this letter, please call 
Nandini N. Shridhar, AICP, of my staff at (510) 622-1642. 



completed. 



Sincerely, 



HARRY Y.YAHATA 
District Director 



By 




JEANC R. FINNEY 
District Branch Chief 
IGR/CEQA 



c: Ms. Katie Schulte (State Clearinghouse) 



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VIII. SUMMARY OF COMMENTS AND RESPONSES 

C. WRITTEN COMMENTS AND RESPONSES 

LETTER B - CALIFORNIA DEPARTMENT OF TRANSPORTATION 

B-1) The Draft EIR includes level of service analysis at both the intersection of Mariposa Street / 
Interstate 280 southbound on-ramp and Mariposa Street / Interstate 280 northbound off-ramp 
(see Table 4, pp. 53-54 and Figure 5, p. 55). Also included in Table 4 and Figure 5 is the 
intersection of Pennsylvania Street and the 1-280 southbound on-ramp. These three intersections 
represent the nearest freeway ramps to the project area. 

As stated in the SEIR, the Mariposa Street / Interstate 280 southbound on-ramp intersection 
currently operates at LOS F during both peak hours, and Phase I project traffic would increase 
delays. By 2015, this intersection is scheduled to be signalized due to the nearby Mission Bay 
project. However, by 2015 Phase II project traffic would result in unacceptable conditions at this 
intersection, even signalized: LOS F in the a.m. peak hour and LOS E in the p.m. peak-hour. 
This would be a significant effect, and would not be mitigable, as the intersection capacity would 
be exceeded. The Mariposa Street / 1-280 northbound off-ramp intersection currently operates at 
an acceptable LOS D or better, and would continue to do so until 2015, when Phase II project 
traffic would result in LOS F in the a.m. peak hour and LOS E in the p.m. peak hour. This, too, 
would be a significant, unmitigable impact. The Pennsylvania Street / 1-280 southbound on- 
ramp intersection currently operates at LOS A, and operations would remain acceptable until 
2015, when Phase II project traffic would result in LOS F in the p.m. peak hour. This impact 
could be mitigated by installation of a traffic signal. 

In terms of the effect on the 1-280 freeway, the transportation report prepared for the project 
indicates that, prior to the implementation of Phase II of the project (assumed to be 2015), the 
project would result in no more than about 50 new vehicle trips on the freeway in either direction 
in the a.m. and p.m. peak hours, which would not result in a noticeable change in level of 
service. By 2015, with the assumed buildout of Phase II, the project would add nearly 300 new 
vehicle trips to the freeway in the a.m. peak hour and nearly 650 new vehicle trips in the p.m. 
peak hour, which would represent an increase of up to 15 percent over existing peak-hour traffic 
volumes on 1-280. As stated in the SEIR, other than the Industry Group project components and 
the Illinois Street bridge (Phase I of the project), there are no specific proposals for development 
on Port lands. The SEIR evaluates a reasonably foreseeable development program for 
development of Port lands by 2015, but the program identified in the SEIR is neither approved 
nor certain to occur. 

B-2) The project would not involve any construction on or adjacent to State highway rights-of-way. 



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RECEIVED 

November 3, 2000 

Environmental Review Officer ^ ^^^^ 

1660 Mission Street, Suite 500 CITY & COUNTY OF S.F. 

San Francisco, California 94103 '''IZSS^r' 

Re: Planning Department Case Number 1999.377E RE 7" ED 

State Clearinghouse Number 94123007 ..^ r; . . r- -- 

Subject: Comments on Draft SEIR F l ' i -[vi^iG DEr T 

San Francisco Southern Waterfront 

Ladies and Gentlemen: 

Bode Gravel is providing these comments on the draft SEIR for the San Francisco 
Southern Waterifront, as referenced above. 

1 . The environmental impact analysis of the proposed Bode facility at Pier 92 correctly 
indicates a zero impact, considering that the proposed project will be virtually 
identical to Bode's existing operation at Third and 16^ Streets. For example, Tables 
12 through 15 indicate a net impact of zero pounds of air pollutants from the Bode 
operation. 

We are pleased to see that the draft SEIR (Section VI-A) recognizes that the "No 
Project" alternative would result in net increases in emissions from the Bode facility 
(and others). This is because the City's demand for concrete products will not be 
affected by the proposed project; therefore, the "No Project" alternative would resuh 
in a net increase in impacts (especially traffic and air quality) over Bode's present 
operation. This is because Bode (or its competitors) would supply the City's concrete 
products from more distant locations. 

The draft SEIR does not quantify the increased impact of Bode's contribution to the 
"No Project" Alternative. However, it is clear that the "No Project" Alternative 
results in greater impacts of the Bode operation than would resuh from the project 
proposed by the draft SEIR. 

2. The description of the Bode project (Chapter 2, page 10) indicates that the plant will 
employ 20 persons on site. The draft SEIR fails to mention that Bode will employ an 
additional 30 persons who will drive Bode-owned cement mixer trucks at off-site 
locations. The Bode facility will provide (continue to provide) opportunities for 
employment to its nearby neighbors. Bode is committed to continue its employee 
training program, which allows many young workers to enter the workforce. 

Thank you for consideration of these comments. If you have questions, please contact 
me. 



C- 



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Environmental Review OfTicer 
November 3, 2000 
Page 2 of 3 



Sincerely, 

BODE GRAVEL COMPANY 

c-«V\ 

Dan Boardman 
President 

cc. Fred Cooper, Cooper Environmental 



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VIII. SUMMARY OF COMMENTS AND RESPONSES 

C. WRITTEN COMMENTS AND RESPONSES 

LETTER C - BODE GRAVEL COMPANY 

C-1) The Bode facility, like all of the aggregate-related Industry Group components, would result in 
effects related to the intensity of development - in this case, the amount of concrete produced - 
such as traffic and air quality, and effects related to the location and "footprint" of physical 
improvements, such as changes in surface runoff and potential exposure to or handling of 
hazardous materials. The commenter thus is incorrect in stating that there would be "zero 
pounds" of criteria air pollutants emitted as a result of the Bode facility; rather, as indicated in 
Tables 12 through 15, the five aggregate-related Industry Group facilities, including Bode, would 
result in a net increase of more than 1,000 pounds per day in emissions of nitrogen oxides 
(NOx) - due entirely to increased use of ships to transport aggregate to the project area - and 
lesser increases in the volume of reactive organic gases (ROG) and respirable particulate matter 
(PM-10). Furthermore, while the commenter correctly states that the Bode facility would 
essentially replace the company's existing plant at Third and 16th Streets, as stated on SEIR p. 9, 
the relocation of the Bode facility and other facilities near Islais Creek would result in local 
transportation effects, which are accounted for in the SEIR's analysis of intersection levels of 
service, and local air quality effects, which are described in the SEIR beginning on p. 89. 

Regarding the No Project Alternative, the SEIR does not state that this alternative would result in 
increased emissions, compared to the proposed project. In fact, emissions of NOx would be 
considerably less under the No Project Altemative, which does not assume increased shipping of 
aggregate, than with the project. As stated on SEIR p. 169, however, the No Project Altemative 
would result in a significant cumulative effect related to air quality, as would the project. 

C-2) The additional employment noted by the commenter would not materially affect the SEIR traffic 
analysis, as the additional 30 employees would increase the number of vehicles in the morning 
and afternoon peak hours by 3 percent or less, which would not be enough to alter the level of 
service analyses in the SEIR. (Truck traffic in the analysis is based on production volume, and 
therefore the change in the number of employees would not result in a change in truck traffic.) 
Daily vehicle trip generation would increase by 2 percent or less. With regard to air quality, the 
above-noted increases in trip generation from the additional employees traveling to and from 
work would affect only cars and light trucks, not heavy-duty (diesel) trucks, and therefore would 
result in imperceptible changes in project emissions. Please see also the response to 
Conmient G-1, p. C&R.28, concerning changes in estimated employment. 



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MISSION VALLEY/ rock company 

/ ASPHALT COMPANY 
/ READY MIX COMPANY 

/ 7999 ATHENOUR WAY SUNOL. CA 94686 (925)862-2257 



RECEIVED 

November 3, 2000 

NOV 1 6 2DUU 

Environmental Review Officer PLANNING DEPT 

1660 Mission Street, Suite 500 
San Francisco, California 94103 



Re: Planning Department Case Number 1999.377E 
State Clearinghouse Number 94123007 

Subject: Comments on Draft SEIR , 
San Francisco Southern Waterfront 



Ladies and Gentlemen: 

Mission Valley Rock Company is providing these comments on the draft SEIR for the 
San Francisco Southern Waterfront, as referenced above, As discussed in the EIR, 
Mission Valley is one of the industrial project proponents. We propose to construct an 
aggregate importing operation and an asphalt plant at Pier 92. These comments provide 
some clarification of the details of project that were not addressed in the Draft EIR. 

1 . The Draft EIR correctly identifies various air pollution abatement equipment and 
measures that will be incorporated into these operations. These include the following 
measures: 

■ On-ship water-sprays will be used to moisten aggregate materials on the ship, 
prior to their conveying to on-shore storage bins. 

■ Some aggregate storage will be located indoors. 

■ For the aggregate that is not stored indoors, aggregate piles will be located in 
three-sided bins. Water will be sprayed on these piles, as needed, to abate 
potential wind-blown dust emissions. 

■ Asphaltic cement will be stored in enclosed storage tanks with vents to limit 
emissions of Volatile Organic Compounds (VOC). 

■ The aggregate drum dryer will use a Low-NOx burner. 

■ Potential particulate fi-om the aggregate dryer will be controlled with the use 
of a baghouse fiher. 

These measures are all considered to be the Best Available Control Technology 
(BACT) as defined by the Bay Area Air Quality Management District. Due to the 
capacity of the plant, BAAQMD will require use of BACT; therefore Mission Valley 
has incorporated these mitigation measures. 



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Environmental Review Officer 
Novembers, 2000 
Page 2 



2. Mission Valley proposes to purchase a new non-portable asphalt plant that can 
incorporate recycled asphalt pavement (RAP) into the paving products. The design of 
the plant will meet the needs of the community for the foreseeable future. The asphalt 
plant will not be a used plant that is transferred from another locatioa 

3. As we have proceeded with the CEQA process, Mission Valley has also applied for 
the required permits with the Bay Area Air Quality Management District. Subsequent 
to filing the application with BAAQMD, we have learned of new ultra-low-NOx 
technology that has been used successfully in asphalt plants in the Los Angeles area. 
Mission Valley is committed to use this newly-defined technology to fiilfiU BACT 
requirements. Specifically, BAAQMD defines BACT for asphalt plants as equipment 
that reduces Nitrogen Oxides emissions to 90 ppm (at three percent oxygen). Mission 
Valley will use Low-NOx burner equipment that achieves Has proposed 36-ppm (at 
three percent oxygen) standard. Use of this equipment will reduce stationary source 
NOx emissions to approximately one-fourth of those indicated in Tables 12, 13, 14, 
and IS. Because the stationary source emissions are much less than the project's 
motor vehicle, truck, ship, and rail emissions, this change does not affect the 
significance determination indicated in the Draft EIR. 

4. In addition, there is experimental technology to control emissions of "blue smoke" 
which comes from asphalt truck-loading operations. This technology has been used, 
sometimes successfully, in the Los Angeles area. Currently, the Bay Area Air Quality 
Management does not recognize this technology (capture of emissions in a truck shed 
and control of the "blue smoke" with use of a fiher pack control system) and does not 
require it to fulfill BACT requirements. Mission VcJley hopes that it's San Francisco 
asphalt plant will be the first and only asphah plant in the Bay Area to incorporate 
this technology. Mission Valley will incorporate the technology that is currently used 
in the Los Angeles are if BAAQMD will accept this technology in its permitting 
program. 

5. The Mission Valley/Bode projects will employ approximately 56 persons, phis will 
support the employment of approximately 10 additional private contractors (such as 
truck drivers). These projects will employ a wide range of job classifications. 
Although some employment will be available for plant managers, plant engineers, 
plant operators, sales staff, clerical and accounting stafl^ a majority of the jobs will be 
trained labor positions (such as truck drivers and vehicle- and plant-maintenance 
stafi)- We anticipate that many of these positions will be filled by residents of the 
nearby Hunters Pomt neighborhood. Clearly, these projects will provide emptoyment 
to residents of the area, 

6. At the October 26, 2000 Hearing before the City of San Francisco Planning 
Commission, neighbors expressed concern that Mission Valley's asphalt plant will be 
built and then expanded to capacities beyond those included in the analysis of the 
draft SEER. This will not happen. Mission Valley has fwoposed a maximum annual 



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Environmental Review Officer 
November 3, 2000 
Page 3 



production of 400,000 tons per year of asphak. This upper limit was proposed in both 
the application to BAAQMD and in the project analysis included in the draft SEIR. 
BAAQMD is expected to propose a permit condition that will limit asphalt 
production to 400,000 tons per year. Mission Valley would accept a similar legal 
limitation as a part of this CEQA process. 

In summary. Mission Valley's proposed operations wiU include brand-new equipment. 
We will use the Best Available Control Technology to reduce potential emissions of air 
pollutants. We propose to be the first and only a^halt plant in the Bay Area to use 
experimental technology to reduce "blue smoke" emissions from truck loading 
operations. (This will likely set the standard for other new asphalt plants in the Bay 
Area.) Our operations will provide jobs for our neighbors. We have been straightforward 
in defining our project, and assure that our voluntary throughput capacity will not be 
exceeded. 

Thank you for consideration of these comments. If you have questions, please contact 
me. 

Sincerely, 

MISSION VALLEY ROCK COMPA>TY 




WilUam Howard 
Vice-President 



cc. 



Mort Calvert, Mission Valley Rock Company 
Fred Cooper, Cooper Environmental 



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VIII. SUMMARY OF COMMENTS AND RESPONSES 

C. WRITTEN COMMENTS AND RESPONSES 

LETTER D - MISSION VALLEY ROCK COMPANY 

D-1) The comment is noted. The assumptions for the asphalt plant analyzed in the SEIR are 

consistent with the description provided. The assumptions (with the exception of the Low-NOx 
drum mixer; see the response to Comment D-3, below) were employed in the air quality analysis, 
and most are described in the Project Description (SEIR p. 1 1), and are also included in 
Mitigation Measures C.l and C.2, SEIR pp. 146-147. 

D-2) The comment is noted. The use of reclaimed asphalt pavement (RAP) would have a beneficial 
effect in that it would reuse some material that might otherwise be sent to a landfill. The use of 
RAP would not alter the emissions calculations provided in the SEIR. 

D-3) As noted by the commenter, while the reduction in asphalt plant emissions would be a beneficial 
effect of the technology described, there would remain a significant, unavoidable effect in regard 
to overall emissions from the aggregate-related Industry Group components because, as noted by 
the commenter, ship and rail emissions would far exceed stationary source emissions. 

D-4) Please see the response to Comment C-2, p. C&R.12. The total employment of 56 noted by the 
conmienter for Bode and Mission Valley Rock combined includes the additional employment 
noted in response 

D-5) The comment is noted, and is consistent with the analyses in the SEIR. 



The SEIR (p. 10) states that the Bode faciHty would employ 20 and (p. 11) that Mission Valley Rock would employ 10. 
Adding 30 employees, from Comment C-2, would cover the total of 56 cited in Comment D-4. 



Case No. 1999.377E 



Southern Waterfront SEIR 



C&R.16 

ESA 990267 



'"'Hanson 



November 6, 2000 



Ms. Hillary E. Gitelman 
Environmental Review Officer 
1660 Mission Street, Ste. 500 
San Francisco, CA. 94103 



Hanson Aggregates 
Mid-Padfic, Inc. 

3000 Busch Road 
P.O. Box 580 

Reasanton, CA 94566-0808 
Tel. 925 846 8800 



RE-r.lVED 
PLANNING DEPT 




Subject: DEIR - San Francisco Southem Waterfront Planning 
Department Case No. 1999.377E 



Hanson Aggregates Mid-Pacific, Inc. (HAMP) has been assigned the six-acre lease 
recently granted to British Pacific Aggregates (BPA) at Pier 94 and has an option to 
lease an additional four acres from the port if a readymix plant or asphaltic 
concrete plant becomes feasible. Ship unloading, stockpiling and distribution of 
imported aggregates were addressed in the 1997 "Waterfront Plan FEIR". 

As a future tenant, HAMP has an obvious interest in the contents and accuracy of 
the SEIR. Hanson would like to offer the following comments: 

1. In the first paragraph of page S-3, several incorrect assumptions are made 
regarding ship unloading at Pier 94. 

a. The stockpiles are not partially enclosed. 

b. The piles would be about 350 feet shoreward of the wharf, not 150 
feet as stated. 

c. No outdoor storage bins are planned unless they are part of an 
asphaltic concrete plant or a readymix concrete plant. 

2. The statement in the last paragraph on page S-16 that "Aggregate would be 
stored in bunkers, rather than open piles" is incorrect unless the issue is 
restricted to an asphaltic concrete plant or a readymix concrete plant. 

3. Paragraph E3 - Soil Disposal on page S-36 is written in such a way that it 
cannot be understood. An explanation/clarification should appear in the 
FEIR. 

4. Page 13 of the Proiect Description - The same comments applies here as 
do to page S-3, Comment 1. 

a. The stockpiles are not partially enclosed. 

b. The piles would be about 350 feet shoreward from the wharf. 

c. No outdoor storage bins are planned. 



£-1 



E-2 



C&R.17 

ESA 990267 



Southern Waterfront SEIR 



"'Hanson 



6. Page 72. Section HI C. Air Quality Setting - "To be conservative, the 
analysis in this report does not assume implementation of any of the above 
proposed rules or regulations". The reference is to a draft program from the 
Air Resources Board to develop new regulations which, when fully 
implemented, could reduce the statewide cancer risk from diesel exhaust 75 
percent by 201 and 85 percent by 2020. 

The California Air Resources Board adopted the above "Risk Reduction 
Plan for Diesel-fueled Engines and Vehicles" on September 28, 2000, with 
the plan phased in by 2007. It would seem to be prudent, for the Final SEIR 
to recognize and comment on the new regulations, which will reduce all 
emissions quantified in the SEIR. 

Thank you for the opportunity to review this SEIR. 



Very truly yours, 

Lawrence W. Appleton 
Manager of Engineering & 
Environmental Affairs 

LWA:dc 



Case No. 1999.377E 



C&R.18 

ESA 990267 



2 



Southern Waterfront SEIR 



VIII. SUMMARY OF COMMENTS AND RESPONSES 

C. WRITTEN COMMENTS AND RESPONSES 

LETTER E - HANSON AGGREGATES 

E-1) Hanson Aggregates, which since publication of the Draft SEIR has superceded British Pacific 
Aggregates as a member of the Industry Group, would operate an aggregate import terminal at 
Pier 94. Because the storage area proposed would be larger than those at the Bode and RMC 
Pacific ready-mix concrete plants and the Mission Valley Rock asphalt plant, aggregate storage 
would be in open piles, rather than bins, with spray bars provided to ensure adequate moisture 
content to minimize dust. Aggregate would typically arrive with a moisture content of between 
4 percent and 5 percent, and would remain moist in the center of these larger storage piles. 
Water spray would be used as needed to maintain adequate moisture on the surface of the piles. 
Therefore, the effectiveness of dust control would be essentially the same as that assumed in the 
SEIR for the smaller bin-contained aggregate piles, and thus the air quality analysis in the SEIR 
remains valid as described. The following revisions are made to the text of SEIR p. 13 for 
accuracy (new and revised text shown underlined ; deleted text shown in strikethrough ):^ 

British Pacific Aggregates (BPA) would develop a storage facility for the 
waterbome importation of construction aggregates (sand, gravel, and crushed 
stone) to be used in the production of concrete and asphalt. BPA proposes to use 
Pier 94 as the dock for ships that would bring aggregate from out-of-state to 
supplement and/or replace existing local supplies. The aggregate would be 
delivered by self-unloading ships directly to Pier 94, where it would be unloaded 
using on-board equipment and stored in partially enclosed stockpiles in up to 
about six acres on the pier apron, approximately ^^§0 350 feet shoreward of the 
wharf. To minimize dust, BPA would use spray bars to moisten aggregate both 
during unloading and while in storage. BPA proposes to supply local producers 
of ready-mix concrete and asphalt, potentially including Bode Gravel 
Company's ready-mix plant and Mission Valley Rock Company's proposed 
asphalt plant (see above), and RMC Pacific's ready-mix plant concrete (see 
below, p. 15), as well as other existing, smaller concrete producers in the project 
area[foot"o'e] ^j^^j possibly elsewhere. 

Improvements to be constructed would include outdoor storage bins for 
aggregate and sand, and possibly conveyors to move material from ships to 
stockpiles and from one location to another and/or for loading into trucks for 
transport to end users. Front-end loader(s) may also be used for loading trucks. 
As noted above, spray bars would be employed to keep the material moistened 
while in storage, to minimize dust. No new paving would be needed, because 
the BPA storage facilities would be located on an already-paved portion of the 
Pier 94 apron. 

Similar revisions are made on p. S-3, in the summary. 



Note that the references to British Pacific Aggregates and "BPA" are retained in the SEIR because the change to Hanson 
Aggregates as leaseholder has no material effect on the analysis of physical impacts. 



Case No. ] 999. 3 77 E 



C&R.19 

ESA 990267 



Southern Waterfront SEIR 



VIII. SUMMARY OF COMMENTS A^fD RESPONSES 

C. WRITTEN COMMENTS AND RESPONSES 

In addition, the second-to-last sentence in Mitigation Measure C.l (SEIR p. 146 and p. S-30) is 
revised as follows (new text is underlined ): 

Aggregate shall be stored in bunkers at ready-mix and asphalt plants , rather than 
open piles, with water spray (including the use of surfactants, as necessary, to 
bind the water and dust to the aggregate) applied to maintain adequate moisture 
content to control emissions at both production and shipping/storage operations . 

The above revision is also made to the second to last sentence of the second full paragraph on 
SEIR p. 91, and the last sentence on p. S-16 in the Summary. 

E-2) Mitigation Measure E.3, SEIR p. 152 (and p. A-36) is reworded as follows to clarify (new and 

revised text shown underlined ; deleted text shown in strike through ; deleted commas indicated by 
brackets ([])): 

The Port shall contract for[] or require that Port tenant(s) contract for[] disposal 
of any portion of the soil pile on the Bode and Mission Valley Rock sites at 
Pier 92 that cannot be reused for construction projects in accordance with 
applicable waste disposal regulations. Fl Such reuse would also require approval 
of the San Francisco Department of Public Health , for construction projects in 
accordance with applicable waste disposal regulations . 

E-3) The comment is noted. Pending approval of the risk-reduction plan for diesel-fueled vehicles 

was identified in the SEIR on pp. 71-72. Although approved by the Air Resources Board (ARB), 
the plan is not regulatory in nature and will require development by ARB staff of a series of 
regulations aimed at reducing diesel emissions. The SEIR analysis therefore remains valid. To 
acknowledge approval of the plan, the last sentence on SEIR p. 71, continuing to p. 72, along 
with the following sentence, are revised as follows (new and revised text shown underlined ; 
deleted text shown in strikcthrough ): 

The CARB board is scheduled to consider approval of a pproved the draft diesel 
risk reduction plan on September 28, 2000 , and . If the CARB board approves 
the draft plan, it is likely then to direct CARB staff t© will begin development of 
the regulatory program identified in the plan. 



Case No. 1999.377E 



C&R.20 

ESA 990267 



Southern Waterfront SEIR 



RMC PACIFIC MATERIALS ^^m^ 



www. rwcpaclfic. com 



H. W. Reppert, 

Director of Environmental Affairs 
(925) 426-21 13 
FAX: 426-2231 



November 1,2000 



6601 Koll Center Parkway 
P.O. Box 5252 
Pleasanton, CA 94566 




Hillary Gitelman, Environmental Review Officer 
Planning Department, City & County of San Francisco 
1660 Mission Street 
San Francisco, CA 94103-2414 



Subj. Comments on Southern Waterfront SEIR, Case # 1999.377E 

RMC has two principal concerns regarding its proposed operations in the SEIR, namely: (1) 
recognition that our proposed business relocation is within the project area, and (2) recognition that 
projected diesel truck emissions will be reduced as a result of new technologies mandated by the 
California Air Resources Board. 

RMC presently operates at 3'*" and Mariposa streets. Our proposed new location is approximately 5,600 
feet south of our current operation at Pier 80. The 3^** and Mariposa intersection is included in the 
project area Transportation Study prepared by Wilbur Smith Associates for the SEIR. However, in the 
main body of the SEIR it is not clear to us that our current operation is considered in all respects as an 
existing activity for the 2003 time horizon. Under our current lease, and absent an approval to re- 
establish our business to Pier 80, RMC could continue to operate in the project area at 3"* and Mariposa 
beyond 2003. Because we now operate within the project area and would continue to do so over the 
short term, we believe that our relocation should contribute no net increase in environmental impact for 
the SEIR analysis of year 2003. In fact, we believe our relocation will lead to a significant decrease in 
truck-related impacts compared to our current operations in the project area. 

The business projection of 850,000 cu-yd./year for ready-mixed concrete in 2015 is termed 
"conservative" from an environmental impact assessment viewpoint. However, from a commercial 
perspective we regard that projected level of activity to be extreme and unrealistic. Despite the 
increased transportation which that assumption attributes to our business, we believe the associated 
diesel emissions will be mitigated substantially by fiiture CARB regulations, especially those that are 
aimed at diesel particulate. For example, CARB's Diesel Risk Reduction Plan represents California's 
latest effort to significantly reduce diesel PM emissions. This regulatory effort represents a realistic and 
measured method to achieve clean air standards, utilizing a systems approach, which combines low- 
sulfur diesel fiiel, new technology cleaner diesel engines and varied high-tech exhaust after-treatment 
systems. RMC believes that such emerging emissions confrol technology is an important aspect of the 
transportation component that deserves consideration in the SEIR. 




Cc: Eric Woodhouse; Joe Sostaric; Bob McQuoid 



Case No. 1999.377E 



C&R.21 

ESA 990267 



Southern Waterfront SEIR 



VIII. SUMMARY OF COMMENTS AND RESPONSES 

C. WRITTEN COMMENTS AND RESPONSES 

LETTER F - RMC PACIFIC MATERIALS 

F-1) As stated on p. 47 of the SEIR, the traffic analysis is conservative because existing trips, 

including those to the Bode and RMC Pacific plants on Third Street, were not "backed out" of 
the traffic analysis because many of these trips originate at the fringe of or outside the study area 
and thus may not travel through most of the analysis intersections. However, pollutant emissions 
from existing activities, including traffic to and from the Bode and RMC Pacific sites, were 
included in the existing baseline in calculating regional emissions, because the area of analysis 
(i.e., the entire Bay Area Air Basin) is much greater. For the local emissions analysis, the 
change in emissions resulting from the change in location of the facilities and the change in 
method of transporting materials (e.g., from truck to ship) was considered. 

Please see also the response to Comment C-1, p. C&R.12. 

F-2) As stated in SEIR Appendix A, the long-range (2015) analysis assumed a production level based 
on the sum of individual Industry Group members' forecasts, even though the total was greater 
than market conditions might support, resulting in a conservative analysis of future conditions. 

Regarding the proposed new state Air Resources Board regulations, please see the response to 
Comment E-3, p. C&R.20. As noted in that response, the recently adopted risk-reduction plan 
for diesel-fueled vehicles is not regulatory in nature and will require development by ARB staff 
of a series of regulations aimed at reducing diesel emissions. 



Case No. 1999.377E 



C&R.22 

ESA 990267 



Southern Waterfront SEIR 



V 



lAiWI 



WASTE RESOURCE TECHNOLOG 

A WASTE MANAGEMENT COMPANY 



895 Egbert Ave. 
San Francisco, CA 94124 
(415) 822-2175 
(415) 822-3852 Fax 




November 7. 2000 RECEfVED 

NOV 9 2000 

Environmental Review Officer planning hrpt 

1 660 Mission Street. Suite 500 
San Francisco, California 94103 



RE: Comments on San Francisco Southern Waterfront Draft Supplemental 
Environmental Impact Report (DSEIR); Planning Department Case No. 
1999.377E; State Clearinghouse No. 94123007 

Ladies and Gentlemen: 

Waste Resource Technologies (WRT) submits the following comments on the 
subject document. 



Page/Section Comment 

General While the Draft Supplemental Environmental 

Impact Report (DSEIR) was being prepared 
and issued, Waste Resource Technologies 
(WRT) has been involved in ongoing 
discussions with representatives of the Port of 
San Francisco regarding its requirements for 
space. As a result, a second potential site for 
WRT's operation was identified. This potential 
site is Building 6 within Pier 70. A meeting with 
the Pier 70 Advisory Committee to evaluate 
community reaction to this location indicated 
that the community would generally support the 
use of Building 6 rather than Building 116 
because it would further remove the proposed 
WRT operation from residential and 
commercial areas. 



Although a lease arrangement has not been 
finalized and an engineering evaluation of the 
building has not yet been completed, the 
following comments assume that Building 6, 
rather than Building 116, will be the space 
used by WRT at Pier 70. 

1 



Case No. 1999. 377 E 



C&R.23 

ESA 990267 



Southern Waterfront SEIR 



Page/Section Comment 

Because Building 6 is located approximately % 
mile from Building 116 and is also accessed 
via 20**^ and Third Streets, there would be no 
material change to the Transportation or Air 
Quality sections in the DSEIR. The use of 
Building 6 rather than Building 116 does not 
materially affect the Land Use or Hydrology 
and Water Quality sections of the DSEIR. 

The historical significance of buildings within 
Pier 70 (including Building 116) was identified 
In the Waterfront Plan FEIR and a mitigation 
measure was included to require a qualified 
historic preservation architect review the 
proposed renovation plans prior to issuance of 
any demolition or building permit. In the 
DSEIR, Building 1 16 is specifically discussed 
in regard to any exterior changes. It was 
determined that if exterior changes were to be 
made, these changes: 

"...should be consistent with the maritime/industrial 
character of the Pier 70 area, particularly with regard to 
the rear of the building, abutting Michigan Street, 
consistent with the Waterfront Plan Design and Access 
Element direction to presen/e views of the historic 
warehouses (including Building 116)." 

These measures will be reviewed for their 
application to Building 6 and, if applicable, 
implemented prior to the renovation of the 
building. 

The Biological Resources section of the DSEIR 
discusses mitigation measures for the impact 
of pier repair. If the engineering study of 
Building 6 determines that the repair of the pier 
is required, these mitigation measures would 
be applicable and implemented. 

Because Building 6 is located within the 
jurisdiction of the Bay Conservation and 
Development Commission (BCDC), WRT 
would take the appropriate measures to obtain 
any required approvals and/or permits. 



2 



Case No. 1999.377E 



C&R.24 

ESA 990267 



Southern Waterfront SEIR 



I 



Page/Section 



Comment 



Prior to completion of the planned engineering 
study of Building 6, it is unknown whether there 
will be soil excavation or addition of impervious 
surfaces associated with development of the 
site. The Hazardous Materials component of 
the DSEIR already discusses the potential 
hazardous materials that may be present in 
Building 6 or surrounding soils (Tetra Tech, 
1998). If Building 6 is used, the required site 
assessment and mitigation measures to 
manage hazardous wastes and/or 
contaminated soils will be implemented. 

On-site parking for employees and for inbound 
and outbound trucks will be incorporated into 
the site design. 

******************************* 

The following comments on the DSEIR call out 
the changes required to reflect the use of 
Building 6 rather than Building 116 by WRT. 



S-4/A. Project Description 



As discussed above, WRT is proposing to use 
Building 6 in Pier 70. Building 6 was 
constructed in 1944 and has 35,000 square 
feet of interior space. 



6/Table 1 Project Characteristics "Location" column should be changed to list 

Building 6. "Size of Site" column should be 
changed to reflect the building area of 35,000 
square feet. 



8/Figure 2 Project Components 



17 & 18/11. C Project Description 



Figure 2 should be revised to reflect WRT's 
location in Building 6 in Pier 70. 

In the third paragraph of the Section titled 
"Waste Management", the number of 
employees is given as 16. Although this was 
the original estimate of employees transmitted 
in November 1 999, a revised estimate was 
given in May 2000. The revised estimate was 
30 employees. 



Case No. 1 999. 3 77 E 



C&R.25. 

ESA 990267 



Southern Waterfront SEIR 



Page/Section Comment 

This section should be revised to reflect WRT's 
location at Building 6 in Pier 70. 
The final paragraph of this section should be 
revised to indicate that it is within 100 feet of 
the shoreline and subject to BCDC jurisdiction. 



50/Table 2 



51/Table 3 



92/Figure 7 Sensitive Receptors 



107/Table 19 



12in"able21 



As stated above, WRT revised the number of 
employees that will be located at the Pier 70 
site in May 2000. The number should be 30. 
This table should be revised to reflect the 
appropriate number of vehicle trips. 

As stated above, WRT revised the number of 
employees that will be located at the Pier 70 
site in May 2000. The number should be 30. 
This table should be revised to reflect the 
appropriate number of vehicle trips. 

This figure should be revised to reflect the 
location of WRT in Building 6, Pier 70. 

This table should be revised to reflect the 
location of WRT in Building 6, Pier 70. 

This table should be revised to reflect the 
location of WRT In Building 6, Pier 70. 



159/IV.H Historic Architectural 
Resources 



Appendix F/F-5 



IX/lndustry Group 



This section should be revised to reflect the 
location of WRT in Building 6, Pier 70. As 
stated above, if it is determined that this 
mitigation measure is applicable to Building 6, 
it will be implemented. 

This section should be revised to reflect the 
location of WRT in Building 6, Pier 70. 

Please change the address for Waste 
Resource Technologies to 261 5 Davis Street, 
San Leandro, CA 94577. 



4 



Case No. 1999.377E 



C&R.26 

ESA 990267 



Southern Waterfront SEIR 



On behalf of Waste Resource Technologies, thank you for accepting and 
considering these comments. 

Sincerely, 

Waste ResourceTechnologies 




Oack Isola 
General Manager 



Case No. 1999. 377 E 



C&R.27 

ESA 990267 



Southern Waterfront SEIR 



VIII. SUMMARY OF COMMEl>fTS AND RESPONSES 

C. WRITTEN COMMENTS AND RESPONSES 

LETTER G - WASTE RESOURCES TECHNOLOGIES 

G-1) The comments are noted, and the changed location for the proposed Waste Resources 
Technologies (WRT) site will be incorporated in the Final SEIR. No change in the 
transportation or air quality analyses will result, because 20th Street would remain the route to 
and from the WRT facility at Building 6, as it would have been for Building 1 16. 

As noted by the commenter, use of Building 6, which is within 100 feet of the San Francisco Bay 
shoreline, would require approval from the Bay Conservation and Development Commission. 
Accordingly, the last sentence of the first paragraph on SEIR p. 18 is revised as follows (new 
language is underlined ; deleted text is shown in strikcthrough ): 

The project would net require BCDC approval, as it would Ret be within 
100 feet of the shoreline. 

Like Building 116, Building 6 was identified in the Waterfront Plan historic resources survey for 
the Pier 70 area as a potential contributor to a potential Pier 70 historic district. As with 
Building 116, effects related to historic resources in connection with reuse of Building 6 would 
be mitigated to a less-than-significant level through implementation of Mitigation Measure H.l, 
SEIR p. 159, which is revised to account for Building 6 instead of 1 16 in lines 2, 4, and 8. Also, 
the reference to Building 1 16 in the second line of the paragraph introducing Mitigation 
Measure H. 1 is revised to read "Building 6." 

Effects related to hydrology and water quality and potential exposure to hazardous materials, if 
any, would generally be similar at Building 6 to those at Building 1 16. Because Building 6 is 
along the Bay shoreline, existing stormwater flow is directly to the Bay. The WRT reuse of this 
building could result in incremental improvement in water quality, with implementation of 
Mitigation Measures D.2, D.4, and D.5. 

Regarding employment, the increased employment identified by WRT would not materially 
affect the SEIR traffic analysis. An increase of 14 employees, compared to the figure used in the 
SEIR, would increase the number of vehicles in the morning and afternoon peak hours by less 
than one percent, which would not be perceptible against the daily variation in traffic volumes. 
Combined with the additional 30 employees noted in the response to Comment C-2, p. C&R.12, 
no changes in intersection level of service or other effects, such as emissions of criteria air 
pollutants, would result. Therefore, no changes are made to Tables 2 through 6 in Section III.B, 
Transportation, nor are any changes made to Tables 11 through 18 in Section III.C, Air Quality. 
However, the first line of the third paragraph under "Waste Management" on SEIR p. 17 is 
revised to reflect the changed number of employees. 



Case No. 1999.377E 



C&R.28 

ESA 990267 



Southern Waterfront SEIR 



VIII. SUMMARY OF COMMENTS AND RESPONSES 

C. WRITTEN COMMENTS AND RESPONSES 

The following additional revisions to the SEIR are made to accommodate the change in location 
of the WRT component from Building 1 16 to Building 6 (new and revised text shown 
underlined ; deleted text shown in strikcthrough ): 

On p. 6, in Table 1, the third column ("Location") of the entry for Waste Resources 
Technologies is revised to read "Building 6" instead of "Building 116." 

On p. 17, the second full paragraph is changed as follows (and the same changes are made to the 
third paragraph on p. S-4, in the Summary) (Note that the state Historic Resources Inventory 
form for Building 6 states that it was constructed in 1941): 

WRT proposes to lease an existing building at Pier 70, located near 20th and 
Illinois Streets, in the former Union Iron Works complex. The structure, 
identified as Building 6 446, contains approximately 24,000 35.000 square feet 
of interior space. There would be no structural modifications to the exterior of 
the building, which was constructed in 1941 1917 . However, WRT would 
renovate portions of the building's interior to accommodate the MRF. WRT 
would install a sort line with associated screens, conveyors, and other equipment 
for processing of construction and demolition material inside Building 6 44€. In 
contrast to WRT's former outdoor facility at Candlestick Point, all sorting and 
storage of material would be accomplished within Building 6 446. Parking 
would be provided on-site for employee vehicles and for staging of semi-trailer 
transfer trucks. 

Also, the second line of p. 18 is revised to read "Building 6" instead of "Building 1 16." 

On p. 107, in Table 19, the third column ("Location") of the entry for Waste Management is 
revised to read "Building 6" instead of "Building 1 16" and the fourth column ("Size of Site") is 
changed to "35,000 sq. ft." 

On p. 121, in Table 21, the second column ("Location") of the entry for Waste Management is 
revised to read "Building 6" instead of "Building 1 16." 

In addition, SEIR Figures 2 (p. 8) and 7 (p. 92) are revised to show the changed location of the 
proposed Waste Management component. The revised figures appear on the following two 
pages. 



Case No. 1999. 377 E 



C&R.29 

ESA 990267 



Southern Waterfront SEIR 




C&R.30 




SOURCE: Environmental Science Associates, Pittman & Hames Associates. 



1999.377E: Southern Waterfront SEIR (ESA 990267) ■ 

Figure 7 (Revised) 

Sensitive Receptors 



C&R.31 



II 9tzd a3N3l3S 1VlN310illAN3-oi 



Z66SB9SSlVl-ii<OJd 



>l:91 00-Sl-AON pSA! 



ALLIANCE FOR 




A Network of Diverse San Francia i^o Environmental and Neighborhood Organizations 



A CLEAN WATEFRONT 



November 10. 2000 



Hillary Gitelman 
30 Van Ness 

San Francisco, CA 94102 

RE: Southern Waterfront Draft SEIR 



Dear Ms. Gitelman, 



Thank you for this opportunity to comn ent on the DSEIR and the short deadline extension. 
These are comments on behalf of the A jiancc for a Clean Waterfront, a coalition of San 
Francisco environmental organizations ^d neighborhood groups, including San Francisco 
Baykeeper, Communities for a Better E Ivironmcnt, Arc Ecology, India Basin Neighborhood 
Association. San Francisco Tomorrow, Coalition for Better Wastewater Solutions, Urban 
Watershed Project, and the Treasure Isl jjnd Wetlands Project. The Alliance also supports and 
joins the comments submitted by the G< >)den Gate University Environmental Justice Clinic and 
the Golden Gate Audubon Society. Thi i letter is to supplement the extensive comments 
provided by the Coalition for Better Wi ^tewater Solutions on the Alliance's behalf. 

To start off, we would like to mention £i>me of the good ideas behind this project First, it allows 
some businesses that are being displacdc) by development in other parts of the City to relocate 
locally. This will allow San Francisco o keep taxes within City limits and is obviously 
beneficial for all City residents. Second^ the project will generate a small increase in 
employment for about SO people, while fnaintaining the existing jobs that would be lost. If some 
of these companies were forced to leav( iithc City. Again, this is a good thing. Our city needs to 
promote blue-collar living wage jobs, e specially those that are accessible to residents of the 
Bayview Hunters Point neighborhood. Third, it will result in the refurbishment of the grain silos 
at Islais Creek. This gives us an opport ijimty to create a great welcome into Bayview Hunters 
Point for people coming down Third Si "ieet It also considers revitalization of the Pier 70 area, a 
long desired step. And lastly, the proj© :!t's aim to bring together related industries, make use of 
the Port's marine facilities, and keep sup] i^iBis. close to jobsites creates an excellent opportunity 
for both environmental and economic fa ^nefits. 

While we acknowledge that this project -may have a number of benefits to the Port and City, we 
nonetheless have concerns about the prjyject and feel that several areas have been inadequately 
reviewed. We look forward to workingi with the Port and with your office to improve both the 
Hnal document and the proposed projects. 



Case No. 1999.377E 



C&R.32 

ESA 990267 



Southern Waterfront SEIR 



Zl •^i 33Nai3S mN3ioyiANa-oi 



ZB6SBSSSltl-mjd 



as well as interim uses, it is i^ropriate 
improvements that could occur over the 

The only reference to new open space ij 



1NAD£0UAT£ ANALYSIS 
Open Space. 

Although the Port has a mandate to imj^ve public access on the waterfront, the project 
reviewed in this document includes no ! ignificani increase in public access and no improvements 
to existing public open space on Port pr ijperty. Since this supplemental ETR reviews permanent 

(o include some description of prospective open space 
jperiod studied. 

!to the "landscaped open space*" (Page S-7) diat will be 
part of the Pier 90-94 backlands develo] ^ent. This description is inadequate. What proportion 
of the 50-acre site would be dedicated o ^n space? What are the planning code 

c f.i ipievelopment of this size (1.65 million square feet)? 

Would the open space be functional as i ijpublic amenity, or would it be simply setbacks and 
landscaping? How does the Southern \ /[aterfront Advisory Comnittee feel about this proposal? 
How does this impact the ongoing open $pace planning efforts of the Bayview Hunters Project 
Area Committee as well as the Planning !Department'$ own **Belter Nei^borhoods" project? 

Environmental Justice 
The Planning Department met regularly! .with the local community in getting input on this draft. 
Yet there is little acknowledgment in th i document of the documented health problems and 
compromised environment of the resid£ ijits. Indeed the language often seems to minimize the 
impacts of this project on the communit y. For example 



. .maximum 24-hour concentration 
fewer than 20 days per year*' (Page S-1 



"...winds blowing in the direction of 
S.18,95). 18% of365 equals 65 days. 
**a pproximate.lv 65 days per year." 



,t Youngblood Coleman Playground would occur on 
). Plea.se consider replacing the underlined words with 

these residences occur only about 1 8% of the time " (Pages 
Please consider changing the underlined phrase to 



concentrati(fn(of the PM-10 standard) at Youngblood-Coleman 
IS days per year. . .". Please consider changing the 



"...the maximum 24-hour 
Playground would occur on fewer than 
underlined phrase to up to. 

The document refers (on pages 77-78) t :> the documented health problems of the neighborhoods 
suljacent to the project, and states that a 'i'detailed study" of the causes of these problems is 
beyond the scope of the EIR. That is tr ije; but it is a primary responsibility of this document to 
clearly and accurately outline the currei ^ and projected future impacts that could reasonably 
impact the health of the neighborhood, specifically, this document needs to more accurately 
assess the existence and extent of hazar jous soil conditions on the site; and to more accurately 
monitor die air quality in the adjacent r t^identia! neighborhoods that are downwind of the 
project. 

Page 105 lists informal significance crit tria for determining whether the project will have a 
significant effect on hydrology and wat t quality. The PUC has acknowledged the impact that 
combined sewage/stormwater overflow^ (CSOs) have on the Southeast community and has 
developed a list of "community values V;to assess the impact of CSOs on the community. We 
suggest that these values be included intiihis document, and that a bullet be added to the 
significance criteria that could read "negatively impact the quality of life for residents by 
increasing the number and duration of f SOs and increasing exposure to toxic contamination." A 



Case No. J999.377E 



C&R.33 

ESA 990267 



Southern Waterfront SEIR 



ei Med 33N3nS lYlNilOillANa-oi Z6BS8SSSlVl-"OJd tPSl 00-SI-aon piA!»38i| 



discussion of increased health risles to j^ople who fish in the Bay for subsistence would be 
appropriate. 

prcjyid 



The section on hazardous materials 
The Southeast Alliance for Environmejijial 
the area (not including Port property) ii li 
300 hazardous sites. Oiven the acbioM 'jledged 
sites in the area, it seems only appropri -(te 
more thorough inspection and review 
be completed, and the results evaluatec 
probability of toxic discharges into gro jndwate: 



es an inadequate description of the current setting. 
Justice conducted an inventory of hazardous sites in 
{ 1996(7). Their extensive dataha«*. search identified over 
area health concerns and the number of untreated 
that the publicly held Port property be subjected to a 
^t the least, the site history for the entire property should 
Ito gauge the concentration of toxic material and the 
X or air. 



The Islais Creek Rail Bridge is died as 
project; but it also represents a signific 
through the neighborhood. The document 
significant improvement to the Missior 
Southeast neighborhood? That has not 
and in noise resulting from increased 



recommended buffer distance is 1 mile 
1-mile buffer. But this "buffei" recom 



prevailing winds would keep the odors 



standard v.-t. counter~flow drum mixers 



difference between ••warranted" rather 



mitigation for the severe transportation impacts of the 
ijnt source of emissions, and will route rail service directly 

states that rerouting rail traffic will result in a 
iBay neighborhood • but at what cost to the existing 
been analyzed. Specifically, the increase in emissions 
traffic has not been listed in this document. 



njl 



Asphalt Plant 

The analysis of the plant' impacts are c|(^fusing. On Page S-18, it is written that the BAAQMD 

^d acknov^lcdging that residences arc located within that 
ijiendadon Is then contested with two main points • first, 



that a "counter-flow drum mixer" will minimize the odors involved, and second, that the 



away from the affected residences most of the time. 



Provide more information? First, is th( re quantifiable data on the relative odor emissions of 



t. Second, what is entailed in the "more detailed odor 



analysis" sited on Page 95 for sites wh( ije the buffer zone is less than 1 nule? And what is the 



regulatory oversight does the B AAQMp have in such cases? 



^han "required" in referring to this analysis? What 



In discussing the significance of odors 
Rules and Regulations provide a regulsjcoiy 
unlikely event that they would become 
regulatory mechanism would be? Andblea 
Additionally, please discuss the cumult |1 
from the existing Southeast sewage trei liment 
existing and new odors at the communi 
particularly helpful for the graphically 



The Project Description states that ther 
Francisco's city limits. Is there a need 
served effectively? What are the envin^iimcntal justi 
unsightly, and toxic air contaminant? 
Heron's Head Park at Pier 98 for environmental 



tom the asphalt plant. It is written that The B AAMQD 

mechanism to remedy odor complaints in the 
ijrequent. Can you please provide an outline of what the 
se quantify what is meant by "frequent." 
ve impacts of the asphalt plant odors and the smells 
plant and the rendering plant. A map showing the 
y's northern and northwest gateways would be 
: ^clined. 



are currently no private asphalt plants within San 
pr an asphalt plant in the City? Are job sites not being 
ce implications of the siting of this noxious, 
w will this plant impact the schoolchildren who go to 
education classes? 



Air Oualltv 

In several places, this document uses the; prevailing wind direction as a reason to reduce the 
significance of the odor and air quality lipipacts of this document. So it should also be noted that 
the air quality monitoring station whoseidata is used in this document is located at 16th and 
Arkansas Streets, northwest of the area being studied. That means that the prevailing winds, 



Case No. 1999.377E 



C&R.34 

ESA 990267 



Southern Waterfront SEIR 



n Med 33N3I3S 1YiN310illANa-oi 



61 



which are so well quantified on page 
the area away from the pollution monl 
closer to the project? If not, how can 
This raises the question of whether the 
into question the accuracy of the cumu 



and Figure 6, actually direct the pollution produced in 
1 prine station. Was air quality data collected at other sites 
t ije air quality of the affected area be accurately measured? 
i>ackground air quality values are accurate, and also calls 
^tive air quality impacts. 



This document refers to FM-2.5 monit< firing on Page 73. but does not study the impacts. 
Although long-term monitoring has no :jbeen done, the evidence cited here does raise concerns, 
and the document offers no further inf( tination. If the national standard was exceeded last year 
at the 16th and Arkansas station, whici lis located upwind of many of the major pollution sources 
in the area, then the concentrations dov ^wind are certamly higher. The fact that the state has not 
yet imposed standards does not mean t tjat this is not a significant impact; why haven't the PM- 
2.5 concentrations for the project been i^aeasurcd and compared to the national standard? If, as is 
noted here, an implementation plan wil ]| be required by 2006, it is within the scope of this 
document to perform such an analysis. 



6b) ipfy: 



Tables 12-15 go to great lengths to i 
and mobile sources. Why does the docjdment 
The City already has experience with 
pollution impacts. Additionally, why 
rail impacts for the aggregate-related Ir 



regional air pollution impacts from both stationary 
not provide a similar analysis of local impacts? 
c)mcrete plants and should be able to quantity their air 
the document not list the individual truck, ship, and 
justly Group components? 



t hg' 



Hvdrologv 

The description of water quality conditipns 
section begins with a correct statement 
incomplete; then contradicts that by ci 
Institute at Ycrba Buena Island. In fact , 
conditions in the project area because i 
outflows. The best indication of the 
Water Quality Board (RWQCB) desigrjiition 
dismissed with the statement that PUC 
imable to supple data on which to base 
assume that the designation of the RW^CB 
which could include contaminated groijijidwater 
discussion of this point can be found 
Wastewater Solutions. 



(Pages 101-102) is incomplete and misleading. The 
tjhat water quality data specific to the project area is 

water quality data taken by the San Francisco Estuary 
1 this data cannot accurately describe water quality 
icannot measure the water quality at the bayside sewer 
co{[^promised water quality in the area is the Regional 
of Islais Creek as a Toxic Hot Spot; but this is 
staff is contesting the designation. Since the PUC is 
liiis refutation, it is the responsibility of this analysis to 
is accurate, and to identify the probably sources, 
and sewage overflows. A more detailed 
ini^e comments submitted by the Coalition for Better 



Hazardous Materials 

The background of this section is Insuf ^cient. The site histories are incomplete, making it 
impossible to determine the likelihood :^f finding toxic hot spots or plumes at those sites. No 
new site assessments were done, even ^ r^ihere the site histoiy indicates that hazardous material 
could be present The site investigatior ^ that have been done indicate the presence of 
hydrocarbons, volatile organic compoui ijds, and heavy metals. Sevenl sites are subject to 
remediation orders. Yet no tests wen; ( 4>nc, no samples taken, to determine the status of the rest 
of the project area; there is no way to di :tenmne from this document whether there are additional 
areas of concern in this project area, lip document relies on the implementation of the Maher 
ordinance to determine and remedy ha2'ardous waste sites. But this ordinance only take effect if. 
and when, 50 cubic yards of soil arc reonoved. If no action is taken at any of these sites, what 
will be the excess cancer risk for individuals working at the Southern Waterfront? 



Case No. 1 999. 3 77 E 



C&R35 

ESA 990267 



Southern Waterfront SEIR 



SI Med 33N3I3S 1VlN310tllAN3-oi Z66SeSSSl»l-BOJd »[:91 OO-SI-aon pSAjaseii 



Page 122 cites the presence of hydrocar 
that this is not significant because the j 
likelihood of migration of contaminant 
both human and ecological receptors? 

Page 1 23 slates that the review performi ^ 
$ite investigations for Islais Creek. Doejsn 
Sediment study qualify? 



ons and metal in the groundwater at Pier 92, but states 
j>undwater is not used for drinking. What is the 
Ifirough groundwater into the bay? What is the impact to 



Biolopicf ii pftCftiiifPB 
The document only discusses the immci ^ 
wildlife at the Heron* s Head Park wetla ids 
Creek (Pier 94). Please evaluate the impacts 



INADEQUATE MITIGATION MEASURES 



for this EIR did not identify any site assessments or 
*t the Regional Water Quality Control Board Toxic 



ate project area, and fails to examine the impacts on 
, or at the cmeipng wetland at the mouth of Islais 
to these areas. 



Despite our many concerns, there are whys to improve the project. Rrst, the asphalt plants 
should be removed from the project. T^jcre is no need for them or the smells, toxics, and 
ugliness that they bring. The City's asp ijalt need is already being met by the municipal facility 
near the sewage treatment plant and pri' 'jate industry has been getting asphalt from Brisbane for 
years. There is simply no reason to plai ;|5 them in a ncighbodiood already overburdened from 
polluting and unhe£^thy industries 

Second, all potentially polluting procesi should be done indoors. Concrete batch plants can be 
constructed inside buildings in order to minimize fugitive dust and the fly ash handling in the 
grain silos should use the best available technology to add whatever equipment is necessary to 
ensure that none of the fine powdery du at escapes into the air. 

In order to address the project's transpo ijtation related air pollution, a clean fuel program air 
pollution increases must be mandated f >t all fleets. Fleet owners should set out a conversion 
schedule, with clear and enforceable pe f ormance standards, prior to the signing of any leases. 
Industry, the Port of SF, and other reiev ^nt regulatory agencies such as the Bay Area Air Quality 
Management District and the Califomie lAir Resources Board should also develop a regional air 
pollution mitigation plan to address the significant pollution from ships and rail. This will allow 
the public and regulators to monitor pre gress as well as identify actions that may not be working 
to reduce transportation related air pollation 

In respect to congestion impacts, the rai i|onale for mitigation measure B.l is incomprehensible. 
A requirement to simply monitor traffic [until it has reached saturation point (LOS £ or F) seems 
a little too hands-off. Surely, it would I »js more appropriate to implement traffic improvements 
before the problems reach an extreme Ii tVel. Mitigation measures B.2 and C.4 call for a 
Transportation Management Plan to re( yce single-occupancy vehicle traffic at the Pier 94-96 
backlands and at Pier 70. Why is no sij plan considered for the truck traffic generated by the 
Industry Group? If the plan doesn't Inc lude regulation of truck traffic, which represents a quarter 
of the vehicle trips, it has little chance Sf being effective. Please consider expanding the scope of 
the Plan to include regulation of all prol^t tnuffic. In addition, the membership of the 
Transportation Management Agency snpuld include City staff (planning and Muni), a 
representative of the District 10 Supervisor, as well as interested area residents. 

Although the project's stormwater runoff will be kept out of the combined sewer system and 
discharged to the bay after some pre-tre^tment, the increase will nonetheless degrade an already 



Case No. 1999. 377E 



C«feR.36 

ESA 990267 



Southern Waterfront SEIR 



91 «ed 33N3I0S mNH0JIIAN3-ei 266SBSSSlH-»0Jd n-il 00-SI-aon P«a! 



impaired bay. As an innovative and con ifnunity friendly midgation. the Port should apply 
natural stormwater treatment methods tli 4t will improve the Bay's health as well as provide 
recreational amenities to neighbors. Me^ures should include stonnwater treatment wetlands and 
improved park and green space to bufTei hctween the Bay and pollution sources, in addition to 
the already identified pretreatment techr 6logies, "best management practices" and tegulatoiy 
mandates. This will not only protect wa resources, but help the Port meet its other 
responsibilities to promote public uses a rjd fisheries. 

We are also concerned about the impact ijon Page 137 states that people were seen Ashing In 
Islals Creelc; but the stirring of concamir ^ted sediment during dredging for the rail bridge is not 
identified as a human health hazard and lio mitigation is listed. An appropriate mitigation would 
be to require signage warning the public pf health hazards, suggesting refraining from fishing in 
that location for the duration of construe Qion. and'bffering alternative areas where subsistence 
fisher-people could go to avoid these el< yated risks. 

The project's proponents - both the Por pnd the Industry Group - should also recognize the 
important linlc thai the Southern Wateifi (!>ni can provide between the development at Mission 
Bay and Pier 70 and the long neglected 1 Sayview Hunters Point neighborhood. Aesthetically 
pleasing design standju^ should be a fundamental tenet of this project. Buildings to enclose the 
concrete plants and materials handling ai^slnesses, as suggested above, can be designed in an 
economically feasible, yet tasteful, style! ; As elements of the conununlty's northern gateway, 
these buildings and the refurbished graiAisilos can serve as canvasses for murals or other artistic 
displays to evoke the Third Street conic pr*s industrial history and envision the brighter future 
that many residents hope comes througl- leconomic revitalization efforts. 

Finally, this project should use help furtficr long-held San Francisco goal to improve economic 

To that end, the Industry group and Port should 
prioritize the incremental job growth frcjtn this project to Bay view Hunters Point residents and 
others of low income and support the hi "ing of these individuals through contributions to relevant 
education and apprenticeship programs. Bayview Hunters Point has a number of organizations 
has a number of organizations that servi Ithese groups. 



CONCI,TTSION 

The Project's many benefits and good jtoints 
will bring. But its scope can help, as will 
undertake the bold and innovative steps 
impacts resulting from the project. Tak 
waterfront beneficial not Just for the Pa 
surrounding neighborhood's as well 

Thank you for the opportunity to commbnt 
For the Alliance for a Clean Waterfront 



are overshadowed by the numerous impacts that it 
as detract, from it by allowing the financial means to 
to mitigate the air quality, water, aesthetic, and other 
hg these steps will make development along the southern 
T and Industry Group, but for residents of the 



Alex Lantsberg, Sewage and Stormwate:r Committee Co-Chair 
415/647-2539 

wi rteve @ r.t p I i nk .net 



Jennifer Clary, Port Chair 

415/981-1405 

fenclarv@aol.com 



Case No. ] 999. 3 77 E 



C&R.37 

ESA 990267 



Southern Waterfront SEIR 



VIII. SUMMARY OF COMMENTS AND RESPONSES 

C. WRITTEN COMMENTS AND RESPONSES 

LETTER H - ALLIANCE FOR A CLEAN WATERFRONT 

H-1) The Planning Department thanks the commenters for the thoughtful and detailed comments on 
the SEIR and on components of the proposed project. 

The open space noted by the commenters in the SEIR summary, also referenced on p. 24 in the 
project description, is discussed in the context of potential future development space that could 
be constructed on the Pier 90-94 backlands, an area that is under study by the Port and its 
Southern Waterfront Advisory Committee, a citizens' group. Currently, all but 10 acres of the 
Pier 90-94 backlands is designated in the Port's Waterfront Land Use Plan for future maritime 
uses. The Port has targeted this backlands area for further study to determine its potential for 
maritime or non-maritime use. The office and/or research and development uses assumed in the 
SEIR for the Pier 90-94 backlands were analyzed for purposes of providing a general 
understanding of environmental impacts at a very conceptual level, to inform the planning study 
for this area. 

In addition, as stated on p. 24 (and on p. S-8 in the surmnary), public access and recreational 
maritime uses are anticipated to be included in future development at the Pier 70 Mixed-Use 
Opportunity Area. As stated on both p. 23 and on p. S-6, "the Port has not identified specific 
development proposals for" either the Pier 90-94 backlands or the Pier 70 Mixed-Use 
Opportunity Area, and therefore it is not possible for the SEIR to describe potential future open 
space and public access in more detail. For information, it is noted that the Planning Code does 
not require open space in Industrial zoning districts such as those that make up the project area. 
Furthermore, the Design and Access Element of the Waterfront Land Use Plan currently does not 
contain urban design or public access policies for the area south of Pier 70, in light of the 
existing and future industrial nature of much of the Southern Waterfront, and because Piers 80, 
90, 92, and 94-96 are existing developed maritime terminals. The Port could establish specific 
policies applicable to office and research and development uses on the backlands should such 
development be proposed in the future. The area around Pier 70, on the other hand, is identified 
in the Design and Access Element as being appropriate for new public access to the Bay, 
"provided such access does not interfere with ship repair or related maritime activities." As 
noted on p. 24 of the SEIR, the Port plans to issue a Request for Proposals to potential 
developers of the Pier 70 Mixed-Use Opportunity Area, which will include open space and 
public access improvements. The RFP is now due out in spring 2001, rather than late 2000 as 
stated in the SEIR. The RFP will include new open space and public access objectives that 
would be used to evaluate the acceptability of all development proposals for the Pier 70 Mixed- 
Use Opportunity Area. 



Case No. 1999.377E 



C&R.38 

ESA 990267 



Southern Waterfront SEIR 



\~m. SLAtNURY OF COMMENTS AM) RESPONSES 

C •ARITTEN COSLMESTS AND RESPONSES 

In addition to the Pier 90-94 backJands and Pier 70. the SEIR also discusses future open space on 
p. 29. where it is noted that the Cit> plans to convert the existing Hunters Point power plant site 
to c^n space once that plant is dosed. 

H-2) Documented health problems in the Ba\-v iew-Hunters Point neighborhood are included in the 

SEIR on pp. 77 and 78, where a recent study conducted in the area is described. However, after 
consultation with the San Francisco Department of Public Health, the SEIR authors noted that 
the 1997 hospitalization stiidy did not attempt to establish any cause-and-efTect relationship 
between emissions sources and hospitalization rates. 

Tbe suggested edits are acknow ledged. The phrase 'iew er than 25 days per year^ (SEIR p. 93) 
accurately reflects the intent of the EIR authors to characterize the maximum concentration of 
PM-10 as occurring relatively infrequently. The reference in the summary , p. S-17. is revised to 
read 'iiewer than 25 days per \ ear" rather than 'few er than 20 days per year." The phrase 
"approximately 65 da\ s per year" will be added to pp. S-18 and 95 of the Fmal SEIR. 

H-3) Potential soil and groundwater contamination in the project area is discussed extensively in 

Section lUi of the SEIR and in .Appendix E. Monitoring of existing concentrations of criteria 
air pollutants w as not conducted for the SEIR because these data were not necessary to evaluate 
the project impact (not significant with respect to local emissions; see SEIR pp. 89-94) or the 
project contribution to cumulative impacts (assumed significant with regard to PM-10 and diesel 
particulate, see SEIR pp. 96-98).-* It is noted that cimiulative impacts with regard to local 
ccmcentrations of PM-10 and diesel particulate w ould be the prodtict of numerous sources in 
addition to the project 

H-4) The list of "community values" referenced by the commenter refers to a document produced as 
part of an as-yet iivcomplete effort initiated by the Qean Water Program of the San Fnmcisco 
Public Utilities Commission (PUQ with the aim of identify ing and e\ aluating potential 
altemative forms of treatment for both sanitary sewage aixl stormw ater runoff. These 
alternatives, if implemented, could supplement the City 's existing combined sewCT-stormwater 
system, which currently collects both sanitary sewage and stormwater tog^ier and delivers the 
entire flow to three wastew ater treatment plants. On the east side of the City. iiKluding the 
project area, these flows are directed to the Southeast Water PoUutioa Control Plant on Phelps 
StreeL As stated in the SEIR on p. 100. during dry weather, all wastewater is treated to a 
secondary level at the Southeast Plant and discharged into San FraiKisco Bay east of Pier 80. 
During wet w eather, how ever, the volume of stormwater can exceed the capacity of the treatment 
plant (even with use of the North Point plant on North Point StreeL which operates only during 
wet weather), resulting in combined sewer system overflows, or CSOs. of wastew ater and 



^ Note dm ifae analysis of locd cabon monoxide (CO) coocentradoas p i ese ntEd on SEIR pp. 89-91 and in Table 16. p. 90. 
indudes enisling nndside coaceatnooas of CO. modeM on die basis of extsdag traffic vohunes. 



Case No. 1999.377E 



Ci:R.f9 

ES.A. 990267 



SouOtem Waterfront SEIR 



Vm. SUMMARY OF COMMENTS AND RESPONSES 



C. WRITTEN COMMENTS AND RESPONSES 



stormwater that are treated only to a primary level, meaning that settleable solids and floatable 
materials are removed but no biological or chemical processes are used, as with secondary 
treatment. 

The Clean Water Program initiated the Screening of Feasible Technologies (SOFT) study to 
evaluate options to improve the existing wastewater treatment system, potentially including on- 
site treatment of wastewater and/or stormwater through construction of "package" treatment 
plants included in these projects; installation of separate sanitary sewer and stormwater 
collection systems with different levels of treatment; use of natural or constructed wetlands to 
remove contaminants from stormwater; and other techniques. As part of the evaluation process, 
a citizens group was convened that included PUC staff, representatives of other City agencies, 
and members of the public. This group developed a draft list of community values that were 
intended to evaluate the feasibility of alternative treatment technologies, rather than assess the 
impact of CSOs, as suggested by the commenters. The list of community values included public 
health risk; ecological risk (Bay, creeks, ocean); water resource value; system information value; 
public and worker safety; cost and economic impacts; neighborhood impacts (odor, traffic, 
noise); land use; environmental justice; regulatory risk; resource impacts; and community 
enhancement opportunity. As noted, the SOFT study has not been completed, and no consensus 
emerged from the citizens group, nor has City policy emerged to date from the effort. 
Nevertheless, by virtue of the above discussion, the community values most recently discussed 
are included in the Final SEIR. 

As a planning and implementation agency, the PUC appropriately may have policies, objectives, 
and "values" that go beyond the significance criteria used in an EIR to determine an adverse 
physical change in the environment. Whether the project would "substantially degrade water 
quality" is considered in the SEIR based on the Regional Water Quality Control Board beneficial 
uses and water quality objectives, as discussed on p. 105 of SEIR, which are based on public 
health criteria and thus implicitly take into account the "quality of life for residents." As to 
commenter's suggested addition to the list of significance criteria for analysis of hydrology and 
water quality impacts concerning an increased number and duration of CSOs, while the SEIR 
bases its significance determination with regard to hydrology and water quality in part on the 
potential increase in CSO volume, it should be noted that any interpretation as to whether or not 
an increase in number or duration of CSOs would "substantially degrade water quality" must be 
evaluated with respect to compliance with RWQCB's NPDES permit requirements for allowable 
CSOs, since the permit requirements account for the Total Maximum Daily Load (TMDL) 
process. (See the response to Comment 1-3, p. C&R.63, for additional information about 
TMDL.) 

As for the suggested addition of "increasing exposure to toxic contamination" as a significance 
criterion, including with regard to persons who fish in the bay, first, without substantial 



Case No. 1999. 377 E 



C&R.40 

ESA 990267 



Southern Waterfront SEIR 



VIII. SUMMARY OF COMMENTS AND RESPONSES 

C. WRITTEN COMMENTS AND RESPONSES 

degradation of water quality, such exposure would not occur. Second, such effects are analyzed 
in the SEIR in Section III.E, Hazardous Materials. 

Please see also the response to Comment H-14, p. C&R.49 below, for additional discussion of 
bay fishing. 

H-5) As noted above, potential soil and groundwater contamination in the project area as a result of 
past land uses is discussed in Section III.E of the SEIR and in Appendix E. 

H-6) Construction of the proposed Illinois Street Intermodal Bridge over Islais Creek would not, in 
itself, result in any increase or decrease in rail or truck traffic, but would redistribute existing 
traffic and future traffic generated by the Industry Group project components and by increased 
activity at the Port's maritime terminals. As can be seen in Figure 3, SEIR p. 21, with respect to 
rail emissions, the Illinois Street bridge would result in decreased emissions, even in the area of 
the bridge, because rail trips that would otherwise require a four-mile rail journey between 
Pier 80 and Piers 94-96 would be reduced to approximately 0.2 miles with the bridge. It is noted 
that existing rails serve Pier 94-96 over the Quint Street Rail Link, between the Union Pacific 
main line and Cargo Way. Similarly, with regard to noise, as indicated in SEIR Figure 3, the 
Illinois Street bridge would not result in trains being closer to any residences, and in fact would 
eliminate some rail traffic along the base of Potrero Hill. Furthermore, based on the assumed 
volumes of cement and fly ash to be hauled by train, the Industry Group components as a whole 
would result in one train load approximately every three days in 2003, and one train load every 
two days in 2015. Given the existing frequency of Caltrain service over much of the same route 
(except for the Quint Street Rail Link between Jerrold Avenue and Cargo Way), the potential 
increase in rail-generated noise would not be meaningful. 

H-7) The PM-10 emissions rate for a drum-type mixer is approximately 30 percent of that of a 
conventional batch mixer. (See the response to Comment K-5, p. C&R.lOO, for additional 
discussion.) As stated on p. 12 of the SEIR, the proposed Mission Valley Rock asphalt plant 
would require an Authority to Construct and a Permit to Operate from the Bay Area Air Quality 
Management District. The District would review the proposed facility, including proposed 
emission-control technology, to ensure that maximum controls are provided and that minimum 
emissions levels would result. 

Concerning the District's procedures for addressing potential odor impacts. Regulation 7 of the 
District's Rules and Regulations provides for a complaint-based mechanism of addressing odor 
impacts. In general, the District must receive 10 or more complaints within a 90-day period for 
the District to take action to evaluate odors. Air samples would be taken and evaluated by the 
District, which can require the correction of any violation of District standards. However, the 
District investigates all complaints. According to the BAAQMD website (www.baaqmd.gov), 
under Air Pollution Complaints, "District inspectors will contact each complainant and will 



Case No. 1 999. 3 77 E 



C&R.41 

ESA 990267 



Southern Waterfront SEIR 



VIII. SUMMARY OF COMMENTS AND RESPONSES 



C. WRITTEN COMMENTS AND RESPONSES 



confirm odor complaints in tiie presence of the complainant whenever possible." If the District 
receives a number of complaints that are traced to a particular plant or facility, the District may 
determine that the facility is creating a public nuisance. The California Health and Safety Code 
and District regulations prohibit emissions of air contaminants that cause nuisance or annoyance 
to a considerable number of people, or that present a threat to public health, or damage to 
property. The District may issue a Notice of Violation, which may prosecuted through either 
administrative, civil, or criminal processes. 

The frequency of odor impacts would be expected to be less often than 65 days per year, in that, 
as stated on p. 95 of the SEIR, winds blow towards the nearest residences at that frequency, but 
odor impacts would require also that the proposed asphalt plant be in operation, which would 
generally be during the daytime, and that atmospheric conditions be stagnant, which would 
generally occur at night. Furthermore, the very fact that stagnant atmospheric conditions would 
be present would tend to diminish odor impacts at off-site locations, because winds would be 
calm. 

There is no standard means of evaluating cumulative odor impacts from different sources, in as 
much as different odors are perceived differently by individuals. Furthermore, wind directions 
that could direct one odor to a particular receptor could direct other odors to different receptors. 

The SEIR does not evaluate the need for asphalt production within the project area, but analyzes 
a specific proposal advanced by one member of the Industry Group. It should be noted, as stated 
on p. 9 of the SEIR, that the Port has not to date indicated support for this proposal. However, 
the proposed asphalt plant was included in the SEIR analysis for purposes of a conservative 
assessment. Concerning Heron's Head Park (Pier 98), odor impacts there from the asphalt plant 
would be similar to those at nearby residences; that is, infrequent. 

H-8) The commenters are correct in stating that prevailing winds in the project area, depicted in 

Figure 6, SEIR p. 65, direct pollutants from the area away from the BAAQMD's Arkansas Street 
station (the nearest monitoring station to the project area). The BAAQMD monitoring stations 
are situated to provide a reasonable representation of air quality conditions over a relatively 
broad geographic area. In general, over a broad area, emissions from motor vehicles represent a 
greater share of total emissions than do emissions from, for example, industrial sources. More 
than 40 percent of reactive organic gases (ROG) emitted in the Bay Area and nearly 50 percent 
of the regional emissions of nitrogen oxides (NOx) - both of which are ozone precursors - are 
emitted by on-road vehicles, compared to 8 percent and 3 percent, respectively, emitted by 
industrial and commercial sources (Bay Area Air Quality Management District, 1997, Figures I 
and 2). The Arkansas Street station is subject to receiving emissions from motor vehicle traffic 
for most of San Francisco. Furthermore, data collected at the PG&E Hunters Point Power Plant, 
at the southeast comer of the project area, in 1992 indicate that ozone and PM-10 levels were 



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VIII. SUMMARY OF COMMENTS AND RESPONSES 



C. WRITTEN COMMENTS AND RESPONSES 



comparable to those reported for the Arkansas Street station in SEIR Table 8^ {Hunters Point 
Shipyard Reuse Final EIR, Case No. 1994.061E, Final EIR certified February 8, 2000; p. PlO-4 
in the comments and responses document). In light of the above, the Arkansas Street monitoring 
data are reasonably representative of conditions for the City. 

It is also true that air quality conditions in San Francisco generally are more favorable than in 
many other portions of the Bay Area, because San Francisco air quality benefits from the 
prevailing winds discussed above, which tend to direct airborne pollutants east and southeast, 
across the Bay. SEIR Tables 8 and 9, pp. 74 and 75, show that, for every 1-hour, 8-hour, and 
24-hour average, for all pollutants, the highest concentration at the Arkansas Street station in 
San Francisco was lower than the highest concentration elsewhere in the Bay Area. 

H-9) As stated on SEIR p. 79, the evaluation of the significance of local particulate concentrations, 
including PM-10 and diesel particulate, is based on the BAAQMD's standards for stationary 
sources; there are no corresponding BAAQMD standards for PM-2.5. The significance criterion 
for PM-10 that was used in the SEIR is 5.0 milligrams per cubic meter (ng/m^) over 24 hours, 
which is far lower than either the state or national 24-hour criteria air pollutant standards for 
PM 10 of 50 lig/m^ and 150 M-g/m^, respectively. Because PM-2.5 concentrations are necessarily 
lower than PM-10 concentrations (because particles of 2.5 microns or less in diameter are 
smaller than those of 10 microns or less in diameter), and because the project's 24-hour average 
concentrations of PM-10 at the modeled sensitive receptors would be no greater than 1.6 pig/m^ 
(in 2015; see Table 17; SEIR p. 94), it is clear that the project's PM-2.5 concentration would be 
substantially below the federal 24-hour standard of 65 fxg/m^. 

H-10) As explained in the discussion of Significance Criteria on SEIR pp. 78-79, for the regional air 
quality analysis, the results of which are summarized in Tables 12-15, "effects are assessed by 
evaluating the total amount of criteria pollutants that the project would emit throughout the Bay 
Area airshed. Based on BAAQMD guidance, this report uses a criterion of 80 pounds per day or 
15 tons per year from indirect sources (such as autos, trucks, trains, and ships) to identify 
projects that generate significant increases in regional emissions of ROG, NO^, or PM-10." 
These criteria, however, do not provide specific information about associated public health risks. 

Use of these criteria is the standard practice for an EIR's analysis of air quality impacts. 
However, as noted in footnote "a" of Table 1 1, SEIR p. 84, "Total project emissions would be 
disbursed throughout the Bay Area," and only a portion of these total emissions would be 
experienced locally. Therefore, the SEIR takes the air quality analysis a step further by 
including analysis of local impacts in terms of public health risk. As stated on SEIR p. 79, this 



The highest one-hour ozone level measured at the power plant was 0.06 ppm, lower than that recorded in four of the Five 
years from 1995 through 1999, as shown in SEIR Table 8. SEIR p. 74. The highest 24-hour average PM-10 level measured 
at the power plant was 68. 1 ng/m. which is slightly higher than the average (66.4 fig/m) and slightly lower than the median 
(71 ng/m) of the highest 24-hour average values for 1995 through 1999, as shown in Table 8. 



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VIII. SUMMARY OF COMMENTS AND RESPONSES 

C. WRITTEN COMMENTS AND RESPONSES 

local analysis "is conducted through dispersion modeling to evaluate the concentration of 
particular pollutants on nearby receptors." Therefore, rather than presenting volumes of criteria 
pollutants for comparison against the 80-pounds-per-day standard, as is done in Tables 12-15, 
the results of the local analysis are summarized in Tables 16-18, and are compared against 
criteria in the form of concentrations in Tables 16 and 17, and risk values in Table 18. 

Regarding truck, rail, and ship emissions attributable to each Industry Group component, the 
SEIR does not break out these calculations by component because the Industry Group 
components represent a substantially closed system. That is, for example, aggregate and cement 
imported by ship, truck, or rail to one component site might be trucked to a second component 
site and processed there for delivery by truck to a user. As described in Appendix A of the SEIR, 
the analysis of aggregate-related impacts is based on an overall production volume that is 
assumed to be generated by the market for construction materials. 

H-1 1) The SEIR does not present contradictory data regarding water quality; rather, it states that "water 
quality data for the Bay specific to the project area are sparse" (emphasis added), and presents 
the data from the Yerba Buena Island sampling station as "the closest sampling station to the 
project area" within San Francisco Bay (SEIR p. 101). Information regarding the Toxic Hot Spot 
designation at Islais Creek, as well as information on the status of San Francisco Bay as an 
"impaired" water body, is similarly presented as factual background data. Please see the 
response to Comment I-l, p. C&R.60, for additional information. 

The SEIR' s analysis of water quality considered potential sources of pollution resulting from 
project components and the amount of new stormwater flow and found that, with the 
incorporation of mitigation measures presented on SEIR pp. 149-150 (implementation of Storm 
Water Pollution Prevention Plans during construction; implementation of Best Management 
Practices; inclusion of on-site stormwater treatment such as oil/water separators and/or grease 
traps; monitoring of stormwater quality prior to discharge; and construction-period monitoring 
and precautions), potential impacts would be reduced to a less-than-significant level. 

H-12) The SEIR analysis of hazardous materials considers not only past land uses that may have 

contributed to existing contamination, but the extensive array of laws and regulations concerning 
hazardous materials, including those governing both handling and disposal of hazardous 
substances. (These regulations are summarized in SEIR Appendix F.) Additionally, review was 
conducted of more than two dozen reports and databases documenting existing conditions on 
portions of the project area. Finally, site visits were conducted as part of the SEIR analysis to 
visually inspect the sites of the Industry Group components and the future Port development 
locations. The commenters correctly note that the SEIR states that sites subject to the Maher 
Ordinance (Article 22A of the Public Health Code) would be subject to further analysis and 
potential remediation prior to development, as described on pp. 129-131 of the SEIR. This 
would be expected to result in site history reports, at a minimum, for nearly all development 



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VIII. SUMMARY OF COMMENTS AND RESPONSES 



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sites. As also stated on p. 131: "For sites not subject to Article 22A because they would involve 
excavation of less than 50 cubic yards, the potential for exposure to subsurface hazardous 
materials is very small, because the amount of soil to be moved would be negligible (the 
equivalent of a 37-foot by 37-foot square one foot deep)." The type of review conducted for the 
SEIR is a standard procedure in CEQA documentation because it provides an adequate 
assessment of whether or not a project would result in significant impacts that could not be 
mitigated. Given the results of the review and site visits, in the context of the stringent 
regulatory framework, the EIR authors concluded that, with mitigation identified in Chapter IV 
of the SEIR, effects related to hazardous materials would not be significant because the project 
would not result in any substantial risk of the release of hazardous materials, would not expose 
workers or the public to hazardous materials, would not create a public health hazard, and would 
not interfere with emergency planning efforts. 

Regarding the presence of hydrocarbons and lead in soil at Pier 92, while there is some overlap 
in the regulatory and analytical framework for handling and disposal of contaminated soil and 
concerns regarding water quality in San Francisco Bay, the discussion in the SEIR's Hazardous 
Materials section is specific to the former. As stated on p. 122, "soil excavated [at Pier 92] could 
be classified as a hazardous waste and would require special handling . . . but because the 
groundwater in this area is not used as a drinking water supply, no remediation would be 
required." 

Regarding the Regional Water Quality Control Board listing of the western portion of Islais 
Creek as a Toxic Hot Spot, this is discussed in the Water Quality section, rather than the 
Hazardous Materials section, because conditions in Islais Creek are likely the result of 
wastewater discharge collected from past activities at numerous locations, including nearby 
former industrial uses as well as possibly discharges of treated wastewater. 

Concerning the potential for adverse effects resulting from groundwater migration to the Bay, 
the project would not result in any changes to groundwater flow patterns, as no major excavation 
or subsurface structures are contemplated as part of the project. 

It should be noted that, while the former landfill at Pier 94 is the subject of a Regional Water 
Quality Control Board closure order - as discussed on SEIR pp. Ill and 123 - and while 
remediation activities have occurred in the past at other locations within the project area (e.g., 
Pier 70, Western Pacific Property), Port staff has indicated that it is not the case that "several" 
sites within the project area are subject to current remediation orders, as claimed by the 
commenter. 

H-13) The following additional description of the wetlands at Pier 94 and Pier 98 is added to the SEIR 
prior to the heading "Regulatory Environment" on p. 138: 



Case No. ] 999. 3 77 E 



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VIII. SUMMARY OF COMMENTS AND RESPONSES 

C. WRITTEN COMMENTS AND RESPONSES 

EXISTING WETLANDS 

Two areas provide small isolated wetland habitat in the Southern Waterfront 
area. One is Pier 98 (developed into Heron's Head Park) and another is at 
Pier 94. Both sites are the result of subsided dredged and fill materials that were 
placed at these locations in the 1970s. These sites contain a total of about 
8 acres of tidally influenced salt marsh habitat. 

Dominant plants at both sites are pickleweed (Salicomia subterminalis) in the 
middle tidal zone and saltgrass (Distichlis spicata) at the upper tidal zone. The 
Pier 94 wetland also contains gum-plant (Grindelia augustifolia) in the upper 
tidal zone, and cordgrass (Spartina sp.) in the lower tidal zone. These species 
are common salt marsh plants of the San Francisco Bay area. 

Heron's Head Park (Pier 98) consists of a developed trail winding along the 
approximately 2,000-foot long peninsula formed by disposal of fill and dredged 
materials in the 1970s. The northern shoreline of this peninsula is steep-sided, 
rip rap within the tidal zone, and has no native vegetation. About 3 acres of 
subtidal environment has formed in several small pockets of subsided materials 
along the unprotected southern shoreline of the peninsula. The subtidal zone is 
vegetated with pickleweed. The upper tidal zone around these pockets contains 
sparse growths of saltgrass bordered by iceplant. Much of the upland portion of 
this Park is non-native ornamental vegetation and wood chips bordering the trail. 

Heron's Head Park seems to be a particularly popular bird- watching area. Many 
of the trailside markers describe birds likely seen in along the Park's shoreline. 
It is likely that the bay waters adjacent to the southern edge of this peninsula are 
warmed by effluent from the PG&E Hunters Point power plant located adjacent 
to the Park. The warmer waters might increase productivity and attract fish and 
fish-eating birds to the area, creating an enhanced source of aquatic bird activity. 

Although there are numerous signs and string borders around native marsh 
vegetation at the Park, the marsh vegetation (i.e., saltgrass and pickleweed) is 
relatively sparse, likely due to the poor quality substrate materials. 

The Pier 94 wetland area occupies a rounded point of land along the southern 
mouth of Islais Creek. Tidally influenced salt marsh habitat has formed in two 
pockets of subsided fill materials along the shoreline. These pockets total about 
5 acres of mostly pickleweed. One of the pockets is slightly higher in elevation 
and contains mostly middle and upper tide zone vegetation (salt grass, 
pickleweed, and gum-plant). The other pocket is lower in elevation with no 
gum-plant, but with a few small bunches of cordgrass in the lower zone and 
surrounded by dense pickleweed. 

The Pier 94 wetland is bounded inland by a large area of dredged and fill 
material that has become upland vegetation with sparse growths of salt bush, 



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VIII. SUMMARY OF COMMENTS AND RESPONSES 

C. WRITTEN COMMENTS AND RESPONSES 

non-native pampas grass, and ice plant. Portions of this upland area are 
currently being used as a construction materials handling and storage area. 

None of the project components would affect the two wetland areas at Pier 98. Pier 98, Heron's 
Head Park, would continue to be designated and managed as a shoreline park. Its primary 
attributes will probably continue to be bird observation and as a walking trail. Without substrate 
restoration activities, the marsh vegetation will likely remain sparse. Upland areas in the Park 
will probably remain non-native for trailside bordering. 

As stated on p. 141 of the SEIR, there would be no encroachment onto the wetlands at Pier 94 
from either the British Pacific Aggregates (now Hanson Aggregates) aggregate import terminal 
at Pier 94 or from the Port's proposed dredge material handling facility, upland from the 
wetlands. The Pier 94 wetland would remain intact and unaffected by current and proposed uses 
of the adjacent upland areas for fill handling and dredged material disposal. Neither of these 
activities would encourage development or human use of the wetlands. Any effluent from the 
disposal of dredged material above this location would be discharged to the bay in accordance 
with water quality permits from the Regional Water Quality Control Board and would not impair 
the wetland site. As noted in the SEIR, the BPA/Hanson aggregate terminal would be located on 
the paved portion of Pier 94, which is developed as one of the Port's existing cargo terminals. 
There is an existing fence that separates the paved portion of Pier 94 from the unpaved area to 
the north that contains the wetlands and the undeveloped backlands of Seawall Lot 352. In 
general, potential impacts to wetlands would be avoided or mitigated due to compliance with 
regulations under the jurisdiction of the U.S. Army Corps of Engineers. Thus, any potential 
impacts would be less than significant. Similarly, potential impacts to special status species 
would be mitigated to a less-than-significant level due to compliance with regulatory 
requirements under the jurisdiction of the U.S. Fish and Wildlife Service and the California 
Department of Fish and Game. Nonetheless, the Port has agreed to implement the following 
measure to further reduce these less-than-significant impacts. 

Prior to the start of any ground-disturbing construction activity on the proposed 
dredge material handling facility at Pier 94, the Port shall engage a qualified 
biologist or other professional to conduct a wetlands delineation of the emergent 
wetlands at Pier 94, just south of the mouth of the Islais Creek Channel. Once 
the delineation is complete and mapped, the Port shall erect a permanent fence 
around the wetlands, including a 200- to 300-foot upland buffer, with allowance 
for pedestrian access for wetlands monitoring and research Detailed design of 
the buffer and fence would be developed as part of a biological assessment to be 
completed (see below). 

Also prior to the start of any ground-disturbing construction activity on the 
proposed dredge material handling facility at Pier 94, the Port shall engage a 
qualified biologist or other professional to conduct a wildlife survey of the 
northeastern portion of the Pier^O-94 backlands; that is, the area between the 



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VIII. SUMMARY OF COMMENTS AND RESPONSES 

C. WRITTEN COMMENTS AND RESPONSES 

emergent wetlands and a line extending northwest to Islais Creek from the 
southwest boundary of the paved portion of Piers 94-96. The biologist shall 
identify any special status plants and animals, and any habitat that supports such 
species in the area. Should special status species or related habitat be identified, 
the Port shall consult with the U.S. Fish and Wildlife Service and the California 
Department of Fish and Game, and shall either reconfigure the dredge material 
storage facility to eliminate potential impacts or relocate the proposed facility to 
avoid the species/habitat. 

As part of the planning process for the Pier 90-94 backlands, and prior to the 
approval by the Port Commission of any development plan for the Pier 90-94 
backlands, the Port shall engage a qualified biologist or other professional to 
conduct a wildlife survey of the southwestern portion of the Pier 90-94 
backlands; that is, the area not included in the above survey. The biologist shall 
identify any special status plants and animals, and any habitat that supports such 
species in the area. Should special status species or related habitat be identified, 
the Port shall consult with the U.S. Fish and Wildlife Service and the California 
Department of Fish and Game, and shall either reconfigure the dredge material 
storage facility to eliminate potential impacts or relocate the proposed facility to 
avoid the species/habitat. 

The Port shall make the results of the above survey(s) publicly available, in the 
form of a Biotic Assessment. The assessment shall include sections on 
methodologies used, persons consulted, description and mapping of sensitive 
habitats, potential impacts and mitigation, and recommendations for 
enhancement and monitoring. The names and qualifications of the report 
preparers shall be included as well. 

H-14) Regarding the asphalt plant(s), it is noted that Alternative B, SEIR p. 169, would not include 
development of any asphalt plants in the project area. 

Concerning indoor ready-mix concrete batch plants, it is noted that these facilities would be a 
relatively small contributor to emissions of criteria air pollutants, in that aggregate-handling 
operations would maintain a moisture content in the aggregate that is high enough to eliminate 
wind-blown dust that could otherwise escape into the surrounding air (SEIR p. 91). In fact, the 
greatest volume of project emissions would be generated ship and rail traffic, particularly on 
days when ships call at the Port's terminals. Therefore, the complete enclosure of concrete 
plants would result in relatively little decrease in emissions. Regarding the fly ash operation 
proposed for Pier 90, as stated on SEIR p. 14, this facility would include enclosure of the 
conveyor system and installation of state-of-the-art dust control systems on the silos and 
conveyor system. 

Because the regulatory environment with regard to diesel engines is rapidly changing, a series of 
measures as part of a clean fuel program is included in Mitigation Measure C.3. SEIR p. 147. 



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VIII. SUMMARY OF COMMENTS ANfD RESPONSES 

C. WRITTEN COMMENTS AND RESPONSES 

which the Port would require its fleet-operating tenants to investigate and report upon. New 
controls on diesel engines are discussed in the SEIR on p. 71. 

Because the intersection impacts included in Mitigation Measure B.l would not occur until 
several years from the present, and only if future development on Port lands were to occur as 
assumed, it is neither feasible nor necessary to impose mitigation now to avoid significant 
impacts. As noted in the response to Comment H-1, above, nearly all of the Pier 90-94 
backlands is designated in the Port's Waterfront Land Use Plan for future maritime uses. Thus, 
the development assumptions used in the SEIR transportation analysis would entail major 
changes in the planning framework and in land uses. The Port plans further study to determine 
whether non-maritime use is feasible on the Pier 90-94 backlands; the SEIR assumed office 
and/or research and development uses to provide a general understanding of environmental 
impacts at a very conceptual level, to inform the planning study for this area. Thus, the rationale 
for Mitigation Measure B.l is to ensure that, should subsequent projects be approved that would 
generate impacts like those described, continual monitoring of traffic conditions would identify 
the time when mitigation would be required for a particular intersection. 

Concerning the Transportation Management Plan identified in Mitigation Measures B.2 and C.4, 
there would be no applicability of measures such as carpooling, increased transit use, and other 
alternative forms of transportation to operation of construction truck fleets. (Truck traffic would 
represent about one-fourth of a.m. peak-hour trips, and about 15 percent of p.m. peak-hour trips 
in 2015, when intersection impacts were found to be significant and unmitigable at several 
locations, and thus would contribute relatively less to congestion in 2015 than would auto traffic.) 

The SEIR (pp. 149-150) includes mitigation measures for stormwater runoff that would reduce 
impacts to a less-than-significant level. Depending on the long-range development proposed on 
Port lands, alternative stormwater treatment strategies could be pursued. Creation of "natural 
stormwater treatment" would be less feasible for interim uses. 

Concerning warning signs to alert persons fishing at Islais Creek, there are existing signs, posted 
by the San Francisco Department of Public Health, at both of the major shoreline open spaces in 
the project area, Pier 98 (Heron's Head Park) and Warm Water Cove. These signs warn, in eight 
languages, of the potential health hazard of eating fish caught in San Francisco Bay, particularly 
shark and striped bass. 

H-15) The commenters' opinions and suggestions are noted. While the SEIR does not identify significant 
environmental impacts related to urban design or aesthetics, and therefore related mitigation is not 
required, these are issues that are regularly considered as part of lease and development approval 
actions. The conrmients regarding economic activity in the project area are noted. 



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« 



VIII. SUMMARY OF COMMENTS AND RESPONSES 

C. WRITTEN COMMENTS AND RESPONSES 

REFERENCES - Response H 

Bay Area Air Quality Management District, Bay Area '97 Clean Air Plan, December 1997 



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i 



® 



November 10, 2000 



1/6 



Environmental Review Officer 
1660 Mission St., Suite 500 
San Francisco, CA 94103 



Re: Comments on San Francisco Southern WateSProni^rail^-BiFl^G* 




RECEIVED 

MOV 1 3 200U 

PLANNING DEPT 



Dear Ms. Gitelman, 

Thank you very much for allowing us a few extra days to get in our comments. We 
sincerely appreciate It. On behalf of The Coalition for Better Wastewater Solutions and 
as co-chair of the Alliance for a Clean Waterfront Stormwater Committee, I write to 
express our concerns about the wastewater issues that may arise from this proposed 
project. We feel that there was an inadequate vetting of relevant information 
concerning these issues - information needed to see the full picture, and that may 
affect the conclusions or mitigations required. We look forward to working with the Port 
and with your office to improve both the final document and the proposed project. 
Herein are our major concerns. 



Islais Creek as a RWQCB-declared "known Toxic Hot Spot ; Potential 
implications Not Accounted For 

There was a seriously inadequate discussion of the fact that the Regional Board has 
declared Islais Creek a" known Toxic Hot Spot" in its "Final Regional Toxic Hot Spot 
Cleanup Plan." Additionally there was but one sentence mentioning the City's 
position: that " the City's PUC "disagrees with the conclusions reached by the 
Regional Board and is currently engaged with the Board in further data collection and 
analysis." 

We believe that much more information is needed on both the RWQCB's conclusions 
and their preliminary assessment of corrective actions, as well as more information 
regarding the City's position and current information gathering . 

We believe this information is highly relevant because it gives a much more complete 
picture of the environmental state of this impaired water body, and what may or should 
be allowed to go in it - regardless of the tussle between the RWQCB and the City over 
whether Islais Creek is actually a "Toxic Hot Spot". It is clearly impaired. 

Secondly, should the RWQCB ultimately decide on some of their proposed corrective 
actions, the situation in Islais Creek could be much more restrictive that this EIR 
currently plans for. Given the advanced stage of the RWQCB's view on this matter, 
and, given the magnitude of either of the potential corrective actions, it would seem 
that the EIR should take this into account and make additional recommendations 
should this come to pass. 



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The Regional Board Report lists a "Preliminary assessment of actions required to 
remedy of restore the creek that includes the possibility of dredging and sediment 
removal as well as corrective action that could include "reduc(ing) or eliminat(ing) the 
number ot overflows." The PUC, In its 1999 draft Strategic Plan for the Clean Water 
Program (dated Nov. 1 998) acknowledges that the City may be faced with a major 
sediment removal project / cost; and that "the City could also be forced to implement 
additional CSO control measures if the data shows continuing sediment problems 
from CSO's." 



While the R WQCB Report acknowledges that a substantial cause of the pollutant 
problem in Islais Creek is historical, ( past polluters, including past discharge of 
primary sewage) it also names the most likely current sources of pollutants are the 
CSO's and the discharges of secondary sewage at the Quint Outfall during wet 
weather discharge conditions. Other pollutant sources, estimated to be minor, but still 
contributors, may include sheet runoff, discharges from business facilities bordering 
Islais Creek, depositions from air emissions (PAH's associated with fossil fuel 
combustion, mercury and other metals are contaminates in diesel exhaust). 

industry Group development will increase the volume of wastewater flows to the 
combined system, and increase direct discharge of stomriwater runoff directly to the 
Bay. Current and new runoff estimates are neariy 50 million gallons per year. While 
the increase due to more impervious surface may be a small percentage, the 
relocation and concentration of industry will add to the pollutant load in the full amount 
of mnoff. 



Insufficient Reporting of : Available Data on Islais Creek ; Potential 
Additional Pollutants; Potential or Upcoming Regulatory Issues 

Again, regardless of whether or not the RWQCB decides to enforce its corrective 
actions, more information should be available on the current conditions of Islais Creek 
and the potential pollutant contribution of the new and relocating industries. Further 
there was an insufficient discussion of known or potentially upcoming tighter 
regulations. All this, it would seem . would be necessary to determine levels of 
significance and provide the City the opportunity to insist on additional mitigations. 

Insufficient Reporting of Available Data on Islais Creek 

The EIR also insufficiently reports on the water quality conditions. On page 101 it 
states that "water quality data for the Bay specific to the project are sparse." 
It then goes on to state that "in general, the Central Bay has the highest water quality in 
the estuary"... and then goes on to use monitoring data from the Verba Buena Island 
sampling station - "the closest sampling station to the project area" - to indicate that 
water quality conditions are "well within water quality objectives." 



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3/6 



We find both those statements to be a bit amazing and misleading, given that there 
have been several studies of Islais Creek, especially due to its listing as a potential 
toxic hot spot by the R WQCB. The RWQCB Toxic Hot Spot Report cites 3 such studies 
done specifically on Islais Creek, (see Attachment 1) 

In addition, the RWQCB issued a Water Code Section 13267 letter (June 1998) 
requiring San Francisco to define the extent of the sediment contamination, and 
determine if the CSO's and Quint Street outfall are continuing the contamination or 
may act to resuspend contaminated sediments already there. San Francisco submitted 
a Sampling and Analysis Plan and in October (1998) started the investigation." 
There is a PUC "Sediment Investigation at Islais Creek Report" submitted to the 
RWQCB In May 1999 that we have requested but have not seen. We do know that 
there were several monitoring stations along Islais Creek for that study. 

In addition, it is reported in the PUC's SOFT Study (Screening of Feasible 
Technologies) that "six overflow stations are involved in the CSO monitoring program" 
(page 3-23) - with Selby Street Outfall(#33), on Islais Creek, among them. 

Why was none of this reported? We believe this relevant data should be part of the 
EIR information Base and analysis. 



Insufficient Reporting of Potential Additional Pollutants from the 
Proposed Development. Its Not Just Sediment. 

There also seems to be a dearth of information with regard to what pollutants might be 
in the wastewater from flushing and dust control, or other such process, or additional 
pollutants that might be added to the stormwater runoff as a result of these proposed 
industrial activities. More complete information might lead the City to different 
conclusions regarding levels of significance or required mitigations. 

The principal concern in the EIR appears to be sediment. Even here there is no 
estimation of what level of particle size may be of concern. Smaller particles are 
known to carry certain types of pollutants, not attached to the larger sized particles that 
the City expresses concern about. 

Totally unaddressed is the issue of what dissolved pollutants there may be in the 
wastewater or stormwater njnoff . Sediment traps will be useless here. As an 
example, with regard to the concrete business wastewater, will ph levels be a 
problem? What is known In terms of potential pollutants from these businesses. The 
City has direct experience with several of them including a concrete business. Waste 
Resources Technology, and Coach USA - as they are relocating. The others are 



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known traditional businesses. What has been their record with regard to their previous 
permits and the City's pollution prevention efforts. Surely more information is known 
about the "new" incoming industries. 

With regard to decant of dredge materials, an assessment should be made of the 
cumulative pollutant load in the area, what upcoming regulatory restrictions may be 
coming, and a restriction on handling of certain types of dredge spoils. 

Because the City has deemed sediment to be the major serious concern, explicit 
measures have been put In the in the mitigations : "Measures shall include ..." 
A full vetting of the potential pollutants and water quality setting should be in the EIR in 
order to give everyone concerned the opportunity to see the full picture and make 
recommendations . 

With a fuller understanding of the picture you may require additional measures 
specifically related to potentially Identified pollutants of concern. Some methods of 
stormwater treatment such as stormwater wetlands, or sand filters require x amount of 
land to be set aside, and set aside in key strategic locations. Without the full picture 
this opportunity to insure that such a land set-aside would be lost. 

Insufficient Reporting of Potential or Upcoming Regulatory Issues 

In addition to the potential restrictions that may be required with regard to the 
RWQCB's Toxic Hot Spot Clean Up Plan, there are other impending regulatory issues 
that may impact the situation. At a minimum, there should be some discussion of the 
implications of the California Toxics Rule and Statewide Implementation Policy and 
the TMDL Process (Total Maximum Daily Load), and more specifics on the regulation 
of stormwater runoff. 

There is, also, no discussion in the EIR of cummulative effects. Along with the addition 
of a fuller disclosure of possible additional pollutants, there should be a discussion of 
cumulative pollutant loads in the Creek and around the mouth of Islais, nearby 
shoreline and the sewage outfall mixing zones. 



1-^ 



Air Born Emissions 

Since other colleagues will address the air born emissions with regard to intake from 
breathing, deposits on land, etc., these comments will only address the issues of air 
born pollutants as they relate to water pollution. Are there any calculations about the 
contribution of the air born pollutants from the proposed projects to Bay and Islais 
Creek pollutant totals? As acknowledged in this EIR as well as the RWQCB Toxic Hot 
Spot Report, airborne emissions are an contributor to Bay pollution. 



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including Islais Creek. Would concentrating these sources near Islais Creek add 
significantly to its burden. 

Concerns About the Nearby Wetlands 

With regard to the proposed development's effect on the two wetlands in the area. It is 
stated that the effects are less than significant. Yet without knowing all the pollutants in 
the stormwater runoff, that conclusion again seems premature. 

In addition to what pollutants may be added to the receiving waters, what are the water 'T ^ / 
current patterns with regard to the existing and proposed discharges and runoff 
patterns? Do the currents cause the migration of pollutants released in one area to 
effect these resources? 

Further, would there be any additional airborne pollutant burden to these habitats. 
Water Recycling 

There was insufficient information on the required or desired use of recycled water, 
beyond the mention of its use for dust control. What is the full required or potential for 
both phases of the development. If its required, where would the source be, and the I"7 
conveyance system? What are the opportunities for on-site or near site creation of 
recycled water. 

Assumption of No New Investment in Wastewater Treatment / 
Infrastructure. A Challenge to the Assumption of ''not... economically 
feasible" ; A Call for a "Screening of Feasible Technologies" for This Site 

The EIR assumes that because of the "interim" use, "neither the Port nor the tenants 
would construct on-site infrastructure related to stormwater collection' (p. 106) 
because, due to the "limited" timeframe, it is not "economically feasible". 

Once again, without a full understanding of the potential pollutants coming from the 
proposed project, nor a contextual understanding within a potentially more restrictive 
regulatory environment, we don't know what may be required or should be done to 
protect the receiving waters. Yet, In fact, some additional means of treatment and 
control may be necessary. Why should these industries not pay for or significantly 
contribute to these additional protections should they be required. If it's economical 
to move here and use City land, located in sensitive areas, then the economics of 
protecting the people and resources of the City should be part of the price. Further, 
until you have a better handle on what may or should be required, how do you know 
its uneconomical. Once again, we, the Board of Supervisors, the past President of the 
PUC Commission have urged, and the City is supposedly investigating a Screening of 



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Feasible Technologies - looking at alternative technologies to see if they can be used 
to help meet the challenges that face the Clean Water Program - to see if they can 
better achieve the environmental treatment needed, and to see if treatment can be 
achieved more economically. While a report has recently been submitted, it was 
roundly criticized as failing to be comprehensive, strategic, and failing to take into 
account critical prerequisite information necessary to make recommendations. We are 
waiting for the PUC to gather the advise of the Technical Review Committee on how to 
correct the work plan to achieve the important goals. In addition, we have called for 
the need for site-specific studies for situations precisely like this - where there is major 
proposed development that could have a significant impact on water quality issues 
that is moving forward at a faster pace than the overall strategic study. In fact, in June 
of 1 998, the focus group of citizens, invited by the PUC to advise them on the SOFT 
study, asked explicitly for additional site specific studies, Including the Port. 

Had that been done, the City might have before it a range of technologies and T~2> 
methods that might be economically feasible for the situation. We urge the City to CoS^. 
immediately conduct such an investigation of both the potential pollutants and 
possible alternative technologies to determine if there is a need and whether there are 
economically feasible solutions. This should be done before certification in order to 
preserve the City's ability to enforce such industry contributions with the power it has in 
this process. 

The goal of the RWQCB's Bay Protection and Toxic Cleanup Program are to address 
enclosed bays, estuaries, or adjacent waters in the "contiguous zone", the pollution or 
contamination of which affects the Interests of the state, where hazardous substances 
(1)may pose a substantial present or potential hazard to aquatic life, wildlife, fisheries, 
or human health, or (2) may adversely affect the beneficial uses of the bay, estuary..., or 
(3) may exceed adopted water quality or sediment quality objectives. 

These are worthy goals. We request that this EIR do a more thorough investigation in 
order to insure that these projects will not add to the environmental burden in this 
already impacted area. 

Thank you for your attention to these matters. 



Sincerely, 




Jeff Marmer 

Coalition for Better Wastewater Solutions 

Alliance for a Clean Waterfront, Co- Chair of Wastewater Committee 



dIus Attachment 1 



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CH2MHill. 1979. Bayside Overflows. Report for City and County of San 
Francisco. 

Hunt, J.W., Anderson, B.S., Phillips, B.M., Newman, J., Tjecrdema, R.S., 
Taberski, K.M., Wilson, C.J., Stephenson, M., Puckett, H.M., Fairey, R., and 
Oakden,J. 1998a. Sediment Quality and Biological Effects in San Francisco 
Bay. pp. 1 18 + Appendices A-E. 

Hunt, J., B. Anderson, B. Phillips, J. Newman, R. Tjcerdema, M. Stephenson, 
M. Puckett, R. Fairey, RSmith, K. Taberski. 1998b. Evaluation and Use of 
Sediment Reference Sites and Toxicity Tests in San Francisco Bay. For Ca. 
State Water Resources Control Board, pp. 1 33 + Appendices A-D. 

Long, E.R. and Markcl. 1992. An Evaluation of the Extent and Magnitude of 
Biological Effects Associated with Chemical Contaminants in San Francisco 
Bay, California. NO AA Technical Memorandum NOS ORCA 64. National 
Oceanic and Atmospheric Administration. 

MEC Analytical Systems Inc. 1996. Sampling and Analysis of Sediment at 
Islais Creek, San Francisco, CA. Report prepared for the City and County of 
San Francisco, Department of Public Works, Water Quality Planning. 

San Francisco Bay Regional Water Quality Control Board (SFBRWQCB). 
1996. Fact Sheet. Prepared by staff of the California Regional Water Quality 
Control Board, San Francisco Bay Region for Amendment of Waste Discharge 
Requirements for Order No. 94-149 for City and County of San Francisco, 
Southeast Water Pollution Control Plant. 

SFBRWQCB. Ambient Concentrations of Toxic Chemicals in San Francisco 
Bay Sediments. May 1998. 

S.R. Hansen & Assoc. 1996. Development and Application of Estuarine 
Sediment Toxicity Identification Evaluations. Prepared for San Jose State 
Foundation, pp. 79 + Appendices A&B. 



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Jeff Marmer 

G. Two-vear expenditure sdwdiite ide^i&rmy.&Didsrtajmplement the plans 
that are not recoverable from poi^aMafefeft^f^ 

In the next two years, we estimate the^lxpcnliture will be $ 1 , 1 00,000. 
This includes the completion of the site investigation and feasibility 
study with Regional Board staff oversight 

Currently, the City and County of San Francisco is funding the site 
investigation. The plan is for the Regional Board to issue a Cleanup and 
Abatement Order to the responsible party or parties subsequent to 
completion of the site investigation, at which point staff oversight costs 
and the feasibility study will be recoverable from that party. 

References 

Advanced Biological Testing Inc. 1998a. Results of Chemical, Physical, and 
Bioassay Testing of Sediments for Maintenance Dredging at Pier 80A, San 
Francisco, California. Prepared for the Port of San Francisco. 

Advanced Biological Testing Inc. 1998b. Results of Chemical, Physical, and 
Bioassay Testing of Sediments for Maintenance Dredging at Pier 80B, San 
Francisco, California. Prepared for the Port of San Francisco. 

Anderson, S.L., Knezovich, J.P., Jelinski, J., and Steichen, D.J. 1995. The 
Utility of Using Pore- Water Toxicity Testing to develop Site-Specific Marine 
Sediment Quality Objectives for Metals. Final Report. LBL-37615 UC-000. 
Lawrence Berkeley National Laboratory, University of California, Berkeley, 
California. 

Chapman, P.M., Dexter, R.N., and Long, E.R. 1987. Synoptic Measures of 
Sediment Contamination, Toxicity and Infaunal Community Composition. The 
Sediment Quality Triad in San Francisco Bay. Marine Ecology Progress Series 
37:75-96. 

City and County of San Francisco, Department of Public Works, Bureau of 
Water Pollution Control. 1990-1993. Tabulated data on Southeast and Islais 
Creek Sediment submitted by Jim Salerno to the California Regional Water 
Quality Control Board, San Francisco Bay Region. 

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VIII. SUMMARY OF COMMENTS AND RESPONSES 

C. WRITTEN COMMENTS AND RESPONSES 

LETTER I - COALITION FOR BETTER WASTEWATER SOLUTIONS 

I-l) As stated on SEIR p. 101, the designation as a Toxic Hot Spot applies to that portion of Islais 
Creek west of Third Street, although the Final Regional Toxic Hot Spot Cleanup Plan from 
March 1999 indicates that the Toxic Hot Spot extends "probably farther east towards the Bay." 
According to the Cleanup Plan, "the most likely source of pollutants are the combined sewer 
overflows" from the City's combined sewer-stormwater system. (There are four wet-weather 
overflow structures that discharge into the western segment of Islais Creek, according to the 
report.) Another "likely source" is the City's treatment plant discharge outfall where Quint 
Street meets Islais Creek. The report continues, "Because of recent improvements in the quality 
of the discharges from these two sources in the past two years, historic discharges are probably 
more of a factor." Other potential sources of pollution in Islais Creek, according to the report, 
include sheet runoff or past discharges from auto dismantlers and metal recycling facilities. 
Finally, deposition from vehicle traffic could also be a minor source of certain contaminants 
such as polynuclear aromatic hydrocarbons, mercury, and other metals. The Regional Water 
Quality Control Board has ordered the City to investigate whether CSOs and the Quint Street 
outfall continue to cause contamination in Islais Creek or may act to re-suspend contaminated 
sediments. As noted in the SEIR, the City Public Utilities Commission is collecting additional 
data on contamination in Islais Creek. 

Regardless of the existing status of Islais Creek, the Industry Group project components would 
increase stormwater flow to the Bay from the project area by about 3 percent (SEIR Table 20, 
p. 1 10), and would treat stormwater flows as provided for in Mitigation Measure D.2, SEIR 
p. 149. With the Best Management Practices and Mitigation Measures identified on SEIR 
pp. 149-150, the 3 percent increase in stormwater runoff would result in little or no net effect on 
Bay water quality, and would therefore be considered less than significant. This is because 
industrial users that would discharge stormwater to the Bay would be required to comply with 
National Pollutant Discharge Elimination System permit regulations that would include 
discharge prohibitions for stormwater containing hazardous substances in excess of established 
quantities; pollutant controls using best available technology economically achievable, best 
conventional pollutant control technology, and best management practices; receiving water 
limitations; preparation and implementation of a Stormwater Pollution Prevention Plan 
(SWPPP); and preparation and implementation of a monitoring program, as stated on SEIR 
p. 103. Such permit requirements could be met through the Industrial Activities Stormwater 
General Permit adopted by the State Water Resources Control Board or through an industry 
specific permit or an individual permit. Techniques employed by the Industry Group 
components could include features such as settling ponds and sediment basins to limit pollutants 
that could reach Bay waters, as stated on SEIR p. 1 1 1. In addition, as also stated on SEIR p. 114. 
"implementation of Mitigation Measure D.2 (implementation of source control Best 
Management Practices consistent with those identified in the Industrial / Commercial Storm 



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Water Best Management Practices Handbook) and of measures identified in the Waterfront Land 
Use Plan EIR (and also presented in Section IV of this report) for tenants to participate in the 
Port's stormwater monitoring program would further reduce the potential for Bay water quality 
degradation." Finally, none of the stormwater from the Industry Group components would be 
discharged into the western portion of Islais Creek, which is designated a Toxic Hot Spot. 

For clarification, the first bulleted point in Mitigation Measure D.2 is revised as follows (new 
language is underlined) : 

prohibiting discharge of process water to storm drains or otherwise directly to 
the Bay or Islais Creek . 

Future Port development, if all stormwater were discharged to the Bay and not directed to the 
combined sewer, would, in combination with the Industry Group components, increase 
stormwater flow from the project area by 29 percent. Again, none of the stormwater would be 
discharged to the western portion of Islais Creek, and Mitigation Measures on SEIR 
pp. 149-150 - including pre-treatment before discharge to the Bay - would reduce impacts of 
increased stormwater flow to a less-than-significant level. Given that project impacts could be 
mitigated, no additional discussion of existing conditions at Islais Creek is required beyond that 
included in the Draft SEIR. 

Concerning water quality data in the SEIR, as noted in the response to Comment H-11, 
p. C&R.44, the SEIR citation of data from near Yerba Buena Island refers to data within 
San Francisco Bay, as opposed to data from specific inlets such as Islais Creek. 

Concerning increases in wastewater flow and the potential effect on combined sewer overflows 
(CSOs), as stated on SEIR p. 106, "the Industry Group components would generate negligible 
wastewater flow, as on-site employment would be relatively small and neither stormwater nor 
process water would be directed to the City's combined sewer system in substantial volumes." 
Therefore, Phase I of the project would not result in any wastewater-related effect on the amount, 
frequency, or volume of CSOs. Phase II - future Port development - could generate an 
estimated 300,000 gallons per day (gpd) of wastewater, or dry weather flows, as also stated on 
SEIR p. 106, based on the development assumptions identified in the SEIR. This would 
represent less than 0.4 percent of the current City wide total of 84 million gallons per day, and 
less than 0.5 percent of the 67 million gallons per day currently treated at the Southeast Water 
Pollution Control Plant. The addition of 300,000 gpd of wastewater - annualized to 
109.5 million gallons - would represent approximately nine times the annual increase in 
stormwater flow from the future Port development sites but only about 10 percent of the 
approximately 1.1 billion gallons per year of total treated effluent anticipated to be generated by 
2015 under the cumulative scenario reported in SEIR Table 20, p. 1 10. Therefore, while it is not 
possible to quantify precisely the effect on CSOs, on an order of magnitude basis, a comparison 



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of the figures in Table 20 appears to indicate that the increase in wastewater would result in an 
increase in CSO volume in Islais Creek of less than 1 percent. Therefore, the impact is 
considered less than significant. 

1-2) The commenter correctly notes that sediment is the major potential water quality concern 

addressed in the SEIR, because several of the Industry Group project components would handle 
large quantities of aggregate, including gravel of various sizes, as well as sand, Portland cement, 
and fly ash. Furthermore, most contaminants in stormwater are adhered to particles, so removal 
of sediment is one of the best ways to minimize stormwater pollution in general. 

As stated by the commenter, the pH (acidity or akalinity) of water discharged from ready-mix 
concrete plants can be of concern. In particular, akaline compounds in Portland cement can 
result in high pH readings that can be harmful to fish and other marine life. As stated in the 
SEIR (p. Ill), each of the Industry Group components would be required to comply with 
National Pollutant Discharge Elimination System (NPDES) permit requirements, which would 
include preparation of a site-specific Stormwater Pollution Prevention Plan. Typically, a NPDES 
permit includes limitations on the contents of water to discharged to a water body such as 
San Francisco Bay, including limits for pH and sediment. In addition, separation process 
wastewater from stormwater would reduce the potential for stormwater to be contaminated. 
Accordingly, the following is added to the bulleted list of potential Best Management Practices 
accompanying Mitigation Measure D.2 on SEIR pp. 149-150 (and in the summary on p. S-33): 

• separating stormwater from process water, such as concrete truck washout water 
and truck wash water, through the use of berms and other features, and ensuring 
that treated stormwater to be discharged to the Bay meets applicable permit and 
regulatory standards, including pH (acidity or akalinity). 

Other dissolved pollutants in stormwater can include heavy metals such as lead, zinc, and 
copper, which originate from motor vehicles and highway structures, moving engine parts, 
automotive lubricating oils, brake pad wear, pesticide and fungicide application, and other 
sources. (Lead concentrations in the roadside environment have declined in the last 20 years 
since the introduction of unleaded gasoline.) Dissolved quantities of petroleum byproducts in 
stormwater also result from motor vehicles and other sources of petroleum combustion. In 
particular, polynuclear aromatic hydrocarbons are contaminants derived from petroleum 
products and combustion of organic materials. Removal of dissolved pollutants, particularly 
metals and particularly at higher concentrations, poses problems even for municipal treatment 
plants, and therefore source control (i.e., avoiding the introduction of these pollutants to 
stormwater in the first place) is often the preferred means of reducing dissolved pollutant loads 
although, in practice, it is difficult to remove roadside pollutants. However, implementation of 
Best Management Practices by the Industry Group components and at Future Port Development 
sites, as described in SEIR Mitigation Measures D.2, D.3, and D.4, would reduce dissolved 



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C. WRITTEN COMMENTS AND RESPONSES 

pollutant loading to the maximum extent feasible by prohibiting discharge of process water to 
storm drains, eliminating pathways for potential spilled materials to enter stormwater, 
intercepting grease and vehicle wash water, and other features coirmionly included in stormwater 
pollution prevention plans. 

Concerning decant water from dredge material, the Port's proposed expanded dredge material 
handling facility would require a permit from the Regional Water Quality Control Board 
(RWQCB), which, as noted on SEIR p. Ill, would require routine testing of the decant water to 
ensure that sediment levels are below accepted criteria, and that the water does not contain 
chemicals (e.g., heavy metals) or other constituents at levels in excess of regulatory 
requirements. Alternatively, this facility could be designed to function without discharge of 
decant water to the Bay. While the Port's continued compliance with regulatory requirements 
can be assured, it would be speculative to project changes to those requirements that could occur 
over time, or specific responses necessitated by those changes that might occur. 

As stated on p. 11 1 of the SEIR, much of the process water used at Industry Group facilities 
would be reused. 

1-3) As described on pp. 101-102 of the SEIR, the Regional Water Quality Control Board (RWQCB) 
has developed a Regional Toxic Hot Spot Cleanup Plan (March 1999) to provide direction for 
the remediation or prevention of toxic hot spots in the San Francisco Bay Region. The western 
segment of Islais Creek was identified as a high priority candidate site in this plan based on 
sediment quality and the status of the benthic community. However, the cleanup of specific sites 
identified in this plan is directly related to overall watershed management plans, the National 
Pollutant Discharge Elimination System and Total Maximum Daily Load (TMDL) processes, 
and stormwater runoff control (discussed below). The City has completed a number of the 
RWQCB 's recommended corrective measures, and currently further site investigation of the 
extent of sediment contamination is required to determine whether and to what extent the 
combined sewer overflows (CSOs) and outfalls are contributing to sediment contamination. 

The TMDL process is provided for in the Clean Water Act, under which states are required to 
identify impaired water bodies and the pollutants causing the impairment. The TMDL process 
requires identifying pollutant sources and allocating the allowable pollutant load to the sources 
to eliminate the impairment. Portions of San Francisco Bay have been identified as impaired for 
a range of pollutants, including mercury, copper, nickel, selenium, polychlorinated biphenyls, 
and pesticides. The RWQCB is now in the process of developing TMDL workplans to address 
the required TMDL allocation and implementation plan for incorporation into the Basin Plan. 
However, the TMDL workplans will vary in their degree of specificity and focus, depending on 
the status of available data on the water quality impairment as well as data on the pollutant 
source. Within the project area, the TMDL process would be incorporated into the NPDES 



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C. WRITTEN COMMENTS AND RESPONSES 

permitting process for wastewater outfalls, CSOs, and stormwater, which is also within the 
jurisdiction of the RWQCB, as described in the SEIR pp. 102-103. 

Stormwater regulations applicable to the proposed project are summarized and discussed on 
pp. 103-104 of the SEIR. More detailed information is available in the Regional Toxic Hot Spot 
Cleanup Plan, cited on SEIR p. 1 14, which is available on line through the California State 
Water Resources Control Board web site (www.swrcb.ca.gov). 

1-4) Table 20 on SEIR p. 1 10, along with the text on p. 109, includes increases in stormwater flow for 
cumulative conditions, based on the Bayside planning model developed for the San Francisco 
Public Utilities Commission. As described in the response to Comment I-l, above, the Industry 
Group components' contribution to cumulative stormwater increases would be very small. 
Increased stormwater flow from future Port development, as assumed in the SEIR, while greater 
in volume, would be subject to Mitigation Measures D.2 and D.3, as described above, that, along 
with permit requirements also described above, would reduce potential water quality effects of 
increased stormwater to a less-than-significant level. 

1-5) As described in the response to Comment H-9, p. C&R.43, project emissions of particulate 
matter would not result in significant effects with regard to human health, even at sensitive 
receptors close to the project area. As noted in the response to Conrmient I-l, above, past 
discharges of wastewater and/or stormwater are believed to be the major cause of existing 
degraded water quality in Islais Creek. The Final Regional Toxic Hot Spot Cleanup Plan 
referred to in the response to Comment I-l, above, states that airborne pollutants from vehicles 
traveling on nearby Interstate 280 and on surrounding streets may contribute to contamination in 
Islais Creek, in that polynuclear aromatic hydrocarbons (PAHs) are associated with fossil fuel 
combustion and mercury and other metals are contaminants in diesel exhaust. However, the 
report concludes, "compared to the CSO and Quint Street outfall contributions, these are 
estimated to be minor sources." Therefore, it is not likely that incremental increases in airborne 
pollutants resulting from the project would substantially degrade water quality in Islais Creek or 
in the Bay. 

1-6) As stated in previous responses to the same commenter, dust and its potential for sedimentation 
is the primary constituent of concern with regard to stormwater runoff from the Industry Group 
sites, but the amount of increased runoff would be so small as to be almost negligible. Similarly, 
as stated in the prior response, airborne pollutants would result in minimal effect. Furthermore, 
any discharge from the project area to the Bay, including stormwater runoff, would be subject to 
the applicable National Pollutant Discharge Elimination System (NPDES) permit requirements, 
which are designed to promote identified beneficial uses, including estuarine and wildlife 
habitat. Please see also the response to Comment H-13, p. C&R.45. 



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1-7) As Stated on p. 1 1 1 of the SEIR, much of the process water used at Industry Group facilities 
would be reused; for example, concrete truck washout water would be incorporated into 
processing of additional concrete. Use of potable water in production operations at Industry 
Group facilities, therefore, would be minimized. Furthermore, there would be relatively low 
employment at these sites, which would also minimize the demand for potable water. 

As for future Port development, as stated throughout the SEIR, there are no specific development 
proposals for the project area other than the Industry Group sites. However, the project area is 
within the Eastside Reclaimed Water Use Area designated by Section 1029 of the Reclaimed 
Water Use Ordinance (approved November 7, 1991), which added Article 22 to Part II, 
Chapter X of the San Francisco Municipal Code (Public Works Code). Within this area, non- 
residential projects over 40,000 sq. ft. (of building area) must provide for the construction and 
operation of a reclaimed water system for the transmission of the reclaimed water within 
buildings and structures. That is, new buildings would need to be designed with separate 
plumbing to service uses that could employ reclaimed water (e.g., toilets). The ordinance also 
requires that owners, operators, or managers of all development projects register their projects 
with the Water Department. The Water Department will issue a certificate of intention to use 
reclaimed water, and reclaimed water shall be used unless the Water Department issues a 
certificate exempting compliance because reclaimed water is not available, an alternative water 
supply is to be used, or the sponsor has shown that the use of reclaimed water is not appropriate. 
Although reclaimed water is available for limited use (e.g., construction dust control) at the 
Southeast Water Pollution Control Plant, there is no widely available reclaimed water in the 
project area. The City has prepared a Recycled Water Master Plan, with implementation 
anticipated within approximately three to five years in the western portion of San Francisco, 
which would be supplied from the Oceanside Water Pollution Control Plant. However, at this 
time, there is no timetable for implementation of the Reclaimed Water Master Plan on the east 
side of San Francisco, including the project area. 

1-8) The text on SEIR p. 106 describes the assumptions under which the analysis of increased 

stormwater flow from Industry Group sites was calculated. The primary point made in the cited 
text is that there would be no connections made between the Industry Group sites and the City's 
combined sewer-stormwater system. The resulting increase in runoff - approximately 
1.4 million gallons per year, or about 3 percent more than under existing conditions - would be 
directed to San Francisco Bay. However, mitigation measures on SEIR pp. 149-150 would, if 
adopted by the Port, require pre-treatment of all stormwater runoff to reduce or eliminate 
potential contaminants that could otherwise reach San Francisco Bay. (As noted in the 
mitigation measures, treatment of runoff could use a variety of approaches, and it is conceivable 
that alternative treatment techniques could be employed as suggested by the commenter in 
connection with future large-scale development.) Similar controls would be imposed on future 
Port development at the Pier 90-94 backlands, at and near Pier 70, and elsewhere. In this way. 



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impacts from increases in stormwater runoff would be reduced to a less-than-significant level. 
Contrary to the commenter's assertion, no significant effects on water quality would occur, as 
stated in the SEIR. 

Please see the response to Comment H-4, p. C&R.40, regarding the Screening of Feasible 
Technologies study regarding alternative strategies for wastewater and stormwater treatment. 



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r 



DOGPATICH 



NEIGHBORHOOD ASSOCIATION 

DATE: November 1, 2000 

TO: Ms. Hillary Gitelman, Environmental Review Officer 

City and County of San Francisco, Planning Department 

FROM: Janet Carpinelli, Corresponding Secretary 
Dogpatch Neighborhood Association 

RE: Dogpatch Community Response to Southern Waterfront Draft SEIR 

L OVERVIEW: 

This response to the San Francisco Southern Waterfront Draft SEIR has been drafted on behalf of 
the Dogpatch Neighborhood Association by members of its executive committee. The Dogpatch 
Neighborhood Association is a grassroots organization of citizens concerned about San 
Francisco's historic Dogpatch neighborhood, generally bounded by Mariposa Street to the North, 
Tubbs Street (23rd) to the south, Highway 280 to the west, and Illinois Street to the east. The 
subject area and proposed projects covered in the Draft SEIR have clear impacts on our 
neighborhood, and on the greater Central and Southern Waterfront Districts. 




By way of background, the Dogpatch Neighborhood Association monitors issues relevant to the 
neighjjorhood and encourages thoughtfial and visionary urban planning that r,espec.ts, celebrates, 
and preserves the character, integrity, and quality of life of the area as it evolves for the 21st 
Century. 

In particular, the proposed projects covered in the Draft SEIR impact several of our 
organization's key issues, including neighborhood improvement, public access to the waterfront 
and local open space, public safety, health and environmental issues, noise and pollution issues, 
transportation, parking and traffic infrastructure planning. Our historic little neighborhood is 
quickly being transformed — but often, it seems, without clear overall planning that considers the 
grand scheme. The Plarming Department is now studying a new master plan for our area as part 
of its Better Neighborhoods 2002 program, however due to the current development boom, by 
the time the study is finished much of our area will already have been forever changed. We believe 
all projects should realistically consider the City's varied needs for residential, commercial, and 
industrial uses in the area, and their cumulative impacts on the fixture of our district. 

We have particular interests in the fiature of Pier 70 and its surrounding area, because it is in the 
heart of our district and we have been planning for public amenities, open space and dynamic 
mixed use development there for years. We respecifiiUy present these comments for review. 



888 Illinois Strtet • San Francisco • California • 9^107 



Case No. 1 999. 3 77 E 



C&R.67 

ESA 990267 



Southern Waterfront SEIR 



Southern Waterfront Draft SEIR Response 
Dogpatch Neighborhood Association 
November 1, 2000 — Page 2 

n. INADEQUACIES OF THE DRAFT SEIR: 

What follows are a range of issues and impacts that we believe are inadequately addressed in the 
Draft SEIR document: 

1. Negative impacts of existing concrete industry in our neighborhood is not adequately 
considered. 

We favor preserving places for industry in the City and in our neighborhood. But we also expect 
industry to be a good neighbor that shows respect for our neighborhood and consideration for 
other businesses and residents that call Dogpatch home. Unfortunately, our historically 
industrial-residential neighborhood (and the greater Central Waterfront district) already has 
significant problems with messy industrial business operations that result in dirt, sand, gravel, 
and grime on our main streets and sidewalks, particularly along Illinois Street and Third Street. 
Further, our area suffers from general lack of maintenance by the City and from offending 
operations that cause the mess — including some businesses that are part of the industry group 
covered in the Draft SEIR. Particularly during this period of booming construction, parts of our 
neighborhood are covered in dust, sand, gravel, and cement debris. For example, the streets 
leading to the existing Bode gravel facility on Third and 16th and the RMC Pacific Materials 
concrete facility on Mariposa are particular problem areas. These are messy operations, whose 
processing facilities and truck fleet traffic result in small concrete spills, potholes, and debris 
covering roads and sidewalks near the facilities. These existing conditions are not covered in the 
Draft SEIR. 

Solution: 

Amend the Draft SEIR to provide a thorough verbal and environmental description of the dust, 
sand, gravel and cement debris and other related impacts in the immediate vicinity of the existing 
operations of Bode Gravel/Mission Valley Rock around Third and 16th and RMC Pacific 
Materials existing ready-mix plant at Third and Mariposa Streets. 

2. Projects that could have a significant cumulative impact on the study area are not 
adequately considered. 

In recent years we have watched the face of our neighborhood change with a wave of fast-track 
dense development and new uses that most other neighborhoods would not be able to 
accommodate (nor tolerate). Some of these uses lack appropriate master planning that considers 
the big picture of the district. We fear the lack of qualitative consideration of other projects will 
cause conflicts in the future — for example, traffic conflicts or needs of residential and 
commercial uses vs. industrial uses. We want uses that will improve our neighborhood. 



Case No. 1 999. 3 77 E 



C&R.68 

ESA 990267 



Southern Waterfront SEIR 



Southern Waterfront Draft SEIR Response 
Dogpatch Neighborhood Association 
November 1, 2000 — Page 3 

Many key projects that we are monitoring in the study area are not factored into the Draft SEIR, 
nor commented upon in any qualitative way. Examples include: 

•Pier 70 Opportunity Area. While covered in the document, since the Draft SEIR was written, 
more has been learned about development plans for this 16-acre site. This includes plans for 
150,000 square feet of new non-profit space, and possibly up to another 500,000 square feet of 
new commercial space. The Pier 70 Opportunity Area project and the masses of people and 
vehicles it will draw will only add to the traffic and congestion problems in our neighborhood, 
and could cause conflicts with the proposed new industries covered in the Draft SEIR. 

•Conversion of the American Industrial Center Buildings from industrial and manufacturing uses 
to much more dense commercial and high tech office uses. This huge building complex provides 
very few parking spaces for its growing number of tenants. This transformation has caused 
increasing traffic congestion and parking problems in the vicinity of Pier 70 and in the Dogpatch 
neighborhood, particularly along Third and Illinois Streets, between Mariposa and 24th Streets. 

•Southern Energy's proposed new 880-megawatt power plant at pier 72, off Illinois Street near 
22nd. This fast-track project, resulting from the City's growing energy needs and the closure of 
the heavily-polluting and inefficient Hunter's Point Power Plant, could have considerable impact 
on our local air quality. : 

•The 175-unit live/work loft complex on Illinois Street between 23rd to 24th proposed by 
Michael Strausz & Company, and dozens of other approved live/work projects in the area 
resulting in hundreds of new residential loft units. Further, according to press reports, many of 
these so-called residential lofts have been illegally converted into office spaces, including: 1025 
17th Street, 1200-1240 22nd Street, 2030 Third Street, 1011 23rd Street, 1099 23rd Street, 1209 
Indiana Street, 1409- 1415 Indiana Street, 1568 Indiana Street, 1001 Mariposa Street, 1020 
Mariposa Street, 696 - 698 Pennsylvania Ave., 701 Pennsylvania Ave., 635 Tennessee Street, 
655 Tennessee Street, and 685 Tennessee Street. These projects will increase vehicle, pedestrian, 
and bicycle traffic in the area. 

•MUNI's Third Street Light Rail line and its impact on truck traffic, particularly along the Illinois 
Street corridor. 

•MUNI's Metro storage and repair facility on Illinois Street and 25th. 



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C&R.69 

ESA 990267 



Southern Waterfront SEIR 



Southern Waterfront Draft SEIR Response 
Dogpatch Neighborhood Association 
November 1, 2000 — Page 4 



•MUNI's approved turnaround on Illinois at 18th. This has the potential to create a horrible 
bottleneck for industrial trucks, big rigs, commuter cars, trains, bicycles, and pedestrians. 

•Designation of Illinois Street as a preferred truck route. 

•Reopening of Illinois Street, between 24th and 25th Streets. This will generate additional truck 
traffic on Illinois. 

•Proposed bike lanes on Illinois Street. We believe the North-South corridor needs safe bike lanes, 
and these lanes have already been refused along Third Street due to the space needs of MUNI 
Light Rail line. 

Solution: 

Revise Draft SEIR to describe and thoughtfully consider implications of all significant projects 
that could impact the area of study — particularly in terms of truck and vehicle movement, 
public safety, congestion and air quality. Suggest ways that the negative effects of these projects 
and the six new industries could be handled in terms of the environmental consequences. If these 
additional projects change the overall conditions of the study area or alter the projected impacts 
of the six new industries, consider additional planning and/or mitigation measures as appropriate. 

3. Bicycle and pedestrian impacts are not adequately addressed.. 

We have concerns that the fleets of trucks serving the proposed new industries will significantly 
increase truck traffic along Illinois Street, Third Street, and key east-west arteries. This increase 
will impact pedestrian and bicycle traffic and safety in areas surrounding the proposed project 
sites, where dense commercial and residential development is taking place and where alternative 
modes of transit are needed beyond Light Rail. The Draft SEIR suggests that the impact between 
bicycles and cars would not be significant because bicycle traffic could be handled on the "variety 
of bicycle routes that are available throughout the project area." However, the bicycle routes 
available are not specifically identified. 



Solution: 

Revise the Draft SEIR to specifically identify the bicycle routes available throughout the area, 
including specifically defined bicycle lanes available on the north-south arteries of Illinois and 
Third Streets, and any key east-west arteries. 



Case No. 1999.377E 



C&R.70 

ESA 990267 



Southern Waterfront SEIR 



Southern Waterfront Draft SEIR Response 
Dogpatch Neighborhood Association 
November 1, 2000 — Page 5 

4. Data on environmental hazards seems inadequate. 

There is limited in-depth discussion of the environmental hazards created by previous and 
current industries throughout the area of the SEIR (noise, air, soil, water, etc.). This makes it 
difficult to consider the additional environmental problems that the six new industries will cause, 
and then, their accompanying mitigations. 

Solution: 

Provide pertinent information regarding the current status of the area covered by this SEIR. 

5. Existing conditions at Pier 70 are not adequately covered. 

Pier 70 has become increasingly congested in recent years, and it will get worse when the 16-acre 
Pier 70 Opportunity Area is developed. The Draft SEIR features minimal discussion of the 
current conditions at Pier 70. This area currently includes San Francisco Drydock, City Tow, the 
Moscone Marshalling Yard, Granny's Movers, B&C Iron & Metal, Underground Construction 
Company, a bus repair facility, the Noonan Building and its 25 tenants, and the American 
Industrial Center complex and its hundreds of tenants. All of these businesses are tightly 
clustered around Illinois Street between 20th and 22nd. They all generate a heavy amount of 
truck, automobile and pedestrian traffic. Further, DPT has designated Illinois and 20th Streets as 
a main route for cars entering and exiting baseball games and events at Pacific Bell Park. The City 
should set an accurate traffic baseline to examine the cumulative impact of the new industry. 

The chart which indicates the Traffic Level of Service Results shows that the intersection of 20th 
and Illinois Streets has a service level of A (p. 53). This is an area of heavy congestion! Those of 
us who live and work in the neighborhood know that this rating is incorrect. MUNI drivers park 
out of service buses along the south side of 20th Street near Third frequently. Commuter cars 
take up all the street parking. Delivery trucks and big rigs frequently double-park while they run 
into local restaurants, stores, and businesses. When large trade shows are in town at Moscone 
Center, it occasionally results in complete grid lock along Illinois Street to 20th Street, as dozens 
of big rigs attempt to enter the Moscone Marshalling yard simultaneously. This level of service 
needs to be reconfirmed as it does not match our personal experience. 

Solution: 

Provide a thorough verbal and environmental description of the Pier 70 area as it is now in order 
to provide a more accurate baseline. 



Case No. 1999. 377 E 



C&R.71 

ESA 990267 



Southern Waterfront SEIR 



Southern Waterfront Draft SEIR Response 
Dogpatch Neighborhood Association 
November 1, 2000 — Page 6 



6. Traffic counts around Pier 70 appear to be inaccurate. 

The chart on p. 53 indicates that the intersection of 20th and Illinois (the entrance to Pier 70) 
maintains an Level of Service of A. Again, we question this finding. This is an intersection of 
considerable vehicular congestion, particularly weekdays between 9am to 5pm, when cars and 
trucks frequently double-park and traffic is most heavy. This intersection is the main route for 
trucks from City Tow, San Francisco Drydock, the Moscone Marshalling Yard, other Pier 70 
tenants and the American Industrial Center tenants and other local industries — in addition to 
standard vehicular traffic. The problem is compounded at this intersection and all along the 
Illinois Street corridor during periods before and after Giants games and other events at Pacific 
Bell Park. We fare concerned that the congestion will be further complicated by the MUNI 
Turnaround at 18th and Illinois Streets, the possible future presence of Waste Resources 
Technologies and its fleet of trucks at Pier 70, and the fleet of trucks serving the other industry 
businesses, which will use Illinois Street as a main route for moving materials. 

Solution: 

Recount the intersection of 20th and Illinois. Expand recount analysis to include the intersections 
of 18th and Illinois, 19th and Illinois, and Mariposa and Illinois. Recount should include peak 
daytime hours, Monday through Friday between Sam and 5pm. Study should also provide 
accurate data for traffic changes when the Marshalling Yard and other Pier 70 and American 
Industrial Center tenants are active. Recount should examine traffic impacts during baseball games 
and other events at Pacific Bell Park in order to confirm that the LOS is currently an A. 



7. Waste Resources Technologies is no longer considering Building 116 at Pier 70. 

The site for the proposed construction and demolition recycling facility to be operated by Waste 
Resources Technologies is no longer building 1 16. The company is now considering an alternative 
light warehouse and lot on the back side of Pier 70 next to San Francisco Drydock. 

Solution: 

Amend the Draft SEIR to reflect the new site of the proposed Waste Resources Technologies 
facility. This should include any alterations planned to the new proposed building, which may be 
an historic resource. 



Case No. 1999.377E 



C&R.72 

ESA 990267 



Southern Waterfront SEIR 



Southern Waterfront Draft SEIR Response 
Dogpatch Neighborhood Association 
November 1, 2000 — Page 7 

8. Planned uses for Waste Resources Technologies at Pier 70 are not clearly defined. 

The Draft SEIR does not indicate whether "Waste Resources Technologies plans to truck in and 
handle asbestos, lead, PCBs, or other hazardous materials at its proposed construction and 
demolition recycling facility adjacent to our neighborhood at Pier 70. Further, it is not clear 
whether this proposed tenant, part of a multi-billion-dollar waste company, plans to operate any 
other related businesses, such as garbage hauling or public recycling facilities for cans, bottles and 
scrap metal. We also have hundreds of homeless and vehicularly housed individuals. "We are 
concerned that these other type of potential uses might ftirther attract homeless scavengers and 
dumpster divers to our area. The community wants to know exactly what is planned for the 
"Waste Resources Technologies operations. We want to improve Pier 70, and do not want this 
historic site to be used as a "dumping ground". 

Solution: 

Revise the Draft SEIR to include information as to whether or not Waste Resources 
Technologies, or any other proposed tenants, plan to handle hazardous materials within the 
study area. Note whether Waste Resources Technologies plans to operate any other related 
businesses that might attract nuisances to the area. 



III. SUGGESTED MITIGATIONS: 

We respectfully suggest the following additional mitigation measures to minimize the potential 
adverse impacts of the project: 

1. Projects would limit public access to our limited waterfront resources. 
Members of the industry group plan to locate non-maritime industrial facilities along much 
desired San Francisco waterfront property, rather than at other potential sites ftirther inland. 
While the proposed projects are allowable uses in areas historically used for industry, members 
of the industry group do not meet critical Public Trust criteria for preferred uses such as maritime 
commerce, navigation and fisheries, public access and open space, environmental restoration, and 
activities which attract public use and enjoyment of the waterfi-ont. The cumulative impact of the 
SEIR projects will limit ability for environmental restoration of the waterfi-ont, as will restrict 
public access to the waterfi-ont. In addition, there is a general lack of parks, open space and 
gardens in the area of study, especially in the increasingly densely developed inland areas. We 
suggest the following: 



Case No. 1999. 377 E 



C&R.73 

ESA 990267 



Southern Waterfront SEIR 



Southern Waterfront Draft SEIR Response 
Dogpatch Neighborhood Association 
November 1, 2000 — Page 8 

a) Require industry group to help support efforts for the public to access and enjoy the 
waterfront within the area of study. For example, help fund restoration of rotting piers within the 
study area for a new local fishing spot. 

b) Require the industry group to jointly fund creation of, or maintenance of, planned or 
existing waterfront parks and open space sites within the district. Possible locations include the 
neglected waterfront park at the mouth of Warm Water Cove, Islais Landing Park, or the 
proposed shipyard park conceived by the community and the Port as part of the Pier 70 
Opportunity Area. 

c) Require the industry group to provide its products or services, at below market rates, for 
projects related to creating or maintaining parks and open space within the area of study. 



2. Traffic congestion & parking problems. 

Parking availability is virtually non-existent during normal business hours along the eastern 
portions of Dogpatch, including most parts of 23rd, 22nd, 20th, 19th, 18th, Mariposa, Third, 
Illinois. The parking crunch is creeping into the chiefly residential streets such as Tennessee and 
Minnesota. We fear that increases in truck and automobile traffic congestion will make it difficult 
for residents and for existing and future industries and businesses to function in the area of the 
SEIR. Without proper planning, the increased industrial traffic will also conflict with other 
existing and planned uses near the study area, including high tech and biotech firms, commercial 
businesses, live/work lofts, non-profit organizations, arts groups, performance spaces, and public 
open spaces. We suggest the following: 

a) Require the development of a truck movement master plan for the entire area of study, 
with particular emphasis on Illinois and Third, from Cargo Way to 16th Street. This plan should 
include the impacts of existing industries, the Third Street Light Rail, Giants game and PacBell 
Park event traffic, and the six new industries. 



b) As a condition of issuing permits to large building owners such as the American Industrial 
Center that grant conversion of industrial/manufacturing spaces into more dense commercial or 
high tech uses, require that the building owners develop a parking mitigation plan for their 
surrounding area. 



Case No. 1999.377E 



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ESA 990267 



Southern Waterfront SEIR 



Southern Waterfront Draft SEIR Response 
Dogpatch Neighborhood Association 
November 1, 2000 — Page 9 

c) Provide a second access point for traffic to enter and exit Pier 70 to help alleviate 
congestion along Illinois and at 20th. Require that 22nd Street be extended into the back side of 
Pier 70 through property leased by City Tow that is currently inaccessible. 

d) Move the MUNI turnaround away from its planned location at 1 8th and Illinois and 
place it instead in the new MUNI storage and repair facility on Illinois Street and 25th. This 
change will ease possible conflicts with truck, train, automobile and bicycle movement in the 
heavily congested area of Illinois at 18th and 20th Streets. 

e) Require industry group to provide its products or services, at below market rates, for a 
project to develop a new City-sponsored or privately-owned multi-level satellite parking facility 
within the area of study (ideally located near Cesar Chavez and the Light Rail Line). Such a 
parking facility would promote public transit, alleviate traffic congestion, and help keep the air 
clean. It would allow auto commuters coming into the City from the Peninsula or South Bay to 
exit the freeway, and then park their cars and transfer to Light Rail for the ride into Dogpatch, the 
Central Waterfront, Mission Bay, and downtown — thus eliminating traffic congestion and air 
pollution in those areas. 

2. Develop and promote better and more diverse alternative transportation plans. 

As Dogpatch and its surrounding area continues to evolve into a more dense area for workers and 
residents, we encourage the City to plan for alternative means of transportation beyond Light 
Rail that will decrease traffic and parking congestion and related air quality problems. This would 
include greater use of options such as MUNI, car pooling, ferry service, bicycling, and walking, 
particularly in the area of Pier 70. We fear that increases in heavy truck traffic in the area of 
study, particularly along the Third Street and Illinois Street corridors, will result in accompanying 
bottlenecks and hazards to pedestrians and bicycles. We suggest the following: 

a) Work with businesses in the area to develop incentive plans that encourage their 
employees to use alternative means of transportation, including public transit, bicycling, car 
pools, and ferry service/water taxis. 

b) Require the development of a bicycle and pedestrian plan for the Illinois Street and Third 
Street corridor, and key east-west streets. This should include safe and convenient bicycle lanes, 
improved signage, clearly marked lanes, safer pedestrian routes, including paved sidewalks and 
adequate cross walks. 



Case No. 1 999. 3 77 E 



C&R.75 

ESA 990267 



Southern Waterfront SEIR 



Southern Waterfront Draft SEIR Response 
Dogpatch Neighborhood Association 
November 1, 2000 — Page 10 



c) If moving the MUNI turnaround away from 1 8th and Illinois is not feasible, require 
MUNI to add a passenger service stop at the 18th street turnaround loop to provide direct access 
to the Pier 70 Opportunity area. 



d) 



See le above. 



3. Noise impacts. 

The proposed Waste Resources Technologies facility adjacent to our neighborhood at Pier 70 
may have some noise impacts related to general operations, fleet traffic, truck safety beepers, 
heavy load dumping, and debris processing. The community must be clear about any possible 
noise problems that could cause conflicts. We suggest the following: 

a) Require Waste Resources Technologies to work with groups such as the Pier 70 Advisory 
Group and the Dogpatch Neighborhood Association to assure that noise levels will not cause 
conflicts with the community and with other local businesses. 

b) If necessary, require Waste Resources Technologies to enclose or muffle work areas so 
that noise levels will be minimized. 



4. Health and environmental issues. 

Health and environmental issues are of grave concern to the people of Dogpatch, Potrero Hill, 
and the Central and Southern Waterfront. Our neighbors in Hunters Point have suffered from 
health-related problems linked to heavy industry in their neighborhoods, such as abnormally high 
rates of cancer and asthma. Hunters Point fought to shut down an inefficient PG&E power plant, 
clean up its ship yards, and the community is now rejecting location of some new industries in 
their community. In addition to the new industries covered in the Draft SEIR, a large new power 
plant project is also being planned for the study area by Southern Energy Company. This project 
could have significant impacts on air quality in our neighborhood, and on the health of our 
children and elderly residents. We suggest the following: 



a) Require the industry group to fund air monitoring stations within the area of study, 
particularly along routes that will be used for heavy industry traffic. Require the industry group 
to monitor air quality within these areas on an ongoing basis, and report its findings to the City 
and to local community groups (such as the Dogpatch Neighborhood Association, the 



Case No. 1 999.377 E 



C&R.76 

ESA 990267 



Southern Waterfront SEIR 



Southern Waterfront Draft SEIR Response 
Dogpatch Neighborhood Association 
November 1, 2000 — Page 11 

Potrero Boosters, and the Pier 70 Advisory Committee) on a regular basis to inform them of 
issues that could impact health and safety. 

b) Require that the industry group's truck fleets use cleaner burning alternative fuels, such as 
natural gas, to minimize levels of air pollution and particulates in the area. 

c) Require industry group to fund tree plantings that will help beautify the neighborhood 
and clean the air. 

5. Sand, gravel, and dirt in our neighborhoods and in the sensitive San Francisco Bav 
environment. 

We are open to a mix of uses, including industry, in our area. However, we will strongly oppose 
these uses if they carelessly pollute our local environment, cause hazards on our streets, or 
endanger the health of the Bay. We are not impressed with how some of the sand, gravel, and 
cement companies covered in this Draft SEIR have soiled our streets with their existing 
operations in our neighborhood. While the new operations would be located in a primarily 
industrial area on the outskirts of our district, their truck fleets will continue to pass through our 
neighborhood. We expect cleaner and more organized operations from all industry companies if 
the project is allowed to move forward. We suggest the following: 

a) Require industry group to monitor dirt and grime levels around its facilities and along the 



b) Require industry group to provide accessible contact persons within their organizations, 
and community clean-up response plans, so community members can report messy operations 
and problems areas and can expect prompt clean up. 

c) Carefully monitor industry group operations. Require them to maintain the area 
surrounding their facilities, and the roads leading to and from their operations, in as clean a 
manner as possible. 

d) Require industry groups to fund extra street cleaning in their areas of operation, and/or in 
other areas throughout the area of study where their heavy truck traffic could cause spilling of 
sand, gravel, dirt, and dust. 



primary routes its truck fleets use within the study area. 




Case No. 1999. 377 E 



C&R.77 

ESA 990267 



Southern Waterfront SEIR 



Janet Carpinelli 

Southern Waterfront Draft ^ilfSW^^fefeii^borho^o^dAssoci^^^ 
Dogpatch Neighborhood Association^ ovember 1, 2000) 
November 1, 2000 — Page 12 (p^ge i of 12) 



e) If industry group operations cause problems with sand, gravel, and dust in the Bay, 
require them to work with Bay environmental agencies and organizations to consider and develop 
appropriate mitigation measures. 



J-12 



Case No. 1999.377E 



C&R.78 

ESA 990267 



Southern Waterfront SEIR 



VIII. SUMMARY OF COMMENTS AND RESPONSES 



C. WRITTEN COMMENTS AND RESPONSES 



LETTER J - DOGPATCH NEIGHBORHOOD ASSOCIATION 

J-1) The commenters' concerns regarding operation of the existing ready-mix concrete plants on 
Third Street at 16th and at Mariposa Streets are acknowledged and are incorporated into the 
Final SEIR by virtue of their appearance in the Summary of Comments and Responses. As 
described in the SEIR, these existing ready-mix plants would be relocated as part of the project 
to Piers 80 and 92, respectively. Therefore, to the extent that the existing plants result in dust 
and dirt on nearby streets, this condition would end. Because the new ready-mix plants would be 
located farther from Third Street than at present, and would be geographically separated from 
residences and from more typical commercial uses than at present, nuisance effects of concrete 
plant operations at the new Industry Group sites would likely be less substantial than described 
by the commenters. In addition, a new mitigation measure is added to the SEIR to require truck 
street sweeping and, for unpaved surfaces, wheel-washing systems, at aggregate facilities (see 
the response to Comment J- 12, p. C&R. 83, below). 

J-2) The comment suggests that the SEIR fails to acknowledge a number of other changes in the 

project area vicinity. On the contrary, the cumulative analysis in the SEIR specifically includes 
several other major projects in the vicinity, including planned development of the Pier 70 Mixed- 
Use Opportunity Area (SEIR p. 24). As noted on p. 24 of the SEIR, the Port will issue a separate 
Request for Proposals to potential developers of the Pier 70 Mixed-Use Opportunity Area 
(although the RFP is now due out in spring 2001, rather than late 2000 as stated in the SEIR); it 
is expected that further environmental review of this development could be required once a 
formal proposal is made for development of the opportunity area. 

Also included in the SEIR cumulative analysis are the proposed expansion of the Southern 
Energy^ Power Plant on Illinois Street (SEIR pp. 29 and 97), and the planned opening of the 
Muni Metro Third Street light rail line and its accompanying maintenance and storage facility on 
Illinois Street and turnaround loop at 18th Street (described on SEIR p. 24 under "Western 
Pacific Property" and assumed in the transportation analysis of conditions in year 2003 and 
beyond; see also SEIR pp. 45 and 59, and note further that the Third Street Light Rail Project 
was the subject of a separate EIR/EIR completed in 1998). The SEIR transportation analysis 
also expressly assumes use of Illinois Street as a truck route, including the block between 24th 
and 25th Streets, once the proposed Illinois Street bridge is constructed. As stated on SEIR 
p. 47, the transportation analysis also accounts for additional background, or cumulative, traffic 
growth due to the Mission Bay project and redevelopment of Hunters Point shipyard and the 
larger Bayview-Hunters Point neighborhood. This is consistent with the direction in 
Section 15130(b)(1) of the state CEQA Guidelines, which permits cumulative analysis to be 
based either on a list of specific project or, as in the SEIR, on growth projections. 



Southern Energy changed its name to Mirant Corp. on Janyary 22. 2001 . 



Case No. 1 999.377 E 



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ESA 990267 



Southern Waterfront SEIR 



VIII. SUMMARY OF COMMENTS AND RESPONSES 



C. WRITTEN COMMENTS AND RESPONSES 



Other land use changes noted by the conimenters are not formal "projects" within the meaning of 
CEQA (i.e., they do not require discretionary approval actions), such as releasing of the former 
American Can Company building (the "American Industrial Center"). Turnover in commercial 
tenants is a normal part of operation of a commercial building, and it would be speculative to 
attempt analysis of future leasing conditions. To the extent that the changes described by the 
commenters have already occurred, however, they are included in the existing conditions 
reported in the SEIR, because the transportation study reflects actual conditions, and are 
therefore part of the future "baseline" to which project impacts are added. The same can be said 
for potentially extralegal conversions of loft space to office use. 

J-3) The SEIR describes bicycle routes serving the project area and bicycle conditions on pp. 44-45, 
and impacts are discussed on pp. 61-62. 

J-4) Please see the response to Comment H-3, p. C&R.39 and the response to Comment H-12, 
p. C&R.44. 

J-5) The intersection levels of service presented in Table 4 (SEIR pp. 53-54) are based on actual 

counts of traffic volumes during the morning and afternoon peak hours that were taken in 2000. 
This is the standard approach to traffic analysis, because it captures commuter traffic, which is 
typically the largest component of traffic at a given intersection. The counts conducted at the 
intersections of 20th and Third Streets and 20th and Illinois Streets would have accounted for 
traffic generated by existing activities at Pier 70, including most of those listed by the 
commenters. An exception is Pacific Bell Park, which does not generate traffic on a daily basis. 
Similarly, there are days when truck traffic to and from the Moscone Center Marshalling Yard, at 
Pier 70, is heavier than on other days. However, the existing intersection levels of service 
presented in the SEIR are intended to represent typical conditions. It is noted that, for signalized 
intersections, such as the two intersections studied on 20th Street, the level of service is based on 
the average delay for all vehicles on all approaches to the intersection. There may be more 
congestion on specific approaches than is indicated by the level of service, although typically 
this would involve fewer vehicles experiencing longer delays. 

Concerning the additional intersections requested for analysis, 18th and Illinois and 19th and 
Illinois are between the intersections of Mariposa and Illinois (which was analyzed) and 20th and 
Illinois, both of which would operate at acceptable levels of service under all scenarios analyzed. 
There is little likelihood that the two intersections in between would operate at conditions much 
worse than those to the north and south. 

J-6) Please see the responses to comment letter G (from Waste Resources Technologies), which 
appears on p. C&R.23. 



Case No. 1999.377E 



C&R.80 

ESA 990267 



Southern Waterfront SEIR 



VIII. SUMMARY OF COMMENTS AND RESPONSES 



C. WRITTEN COMMENTS AND RESPONSES 



J-7) As noted on p. 17 of the SEIR, Waste Resources Technologies would operate a material recovery 
facility for construction and demolition debris, which would reclaim usable materials, including 
metal and wood. Construction and demolition debris is regulated by the California Integrated 
Waste Management Board (CIWMB) as a Class III waste, the least hazardous type of solid waste 
(the same type as household trash). No program would be included to accept loads of consumer 
recyclables, such as cans and bottles. Nor would hazardous materials such as PCBs, lead, or 
asbestos be accepted; handling of hazardous materials requires separate permits from the state 
Department of Toxic Substances Control and other agencies, and Waste Resources Technologies 
does not intend to apply for such permits. Should hazardous materials or wastes be received at 
the Waste Resources Technologies facility at Pier 70, the materials would be isolated and placed 
in a containment area. If the hazardous materials or wastes could be tracked to a specific source, 
that "generator" would be required to remove the materials and/or make arrangements for proper 
disposal. If the materials could not be traced. Waste Resources Technologies would be 
responsible for transport to an appropriate facility for disposal. In this manner, the operation 
would be similar to a transfer station, which is required to have in place procedures for 
responding to inadvertent deliveries of non-permitted materials. 

As a condition of the permits issued by the CIWMB and the Local Enforcement Agency - the 
City of San Francisco in this instance - Waste Resources Technologies would be required to 
implement a load-checking program for hazardous materials and wastes. Drivers are trained to 
recognize hazardous materials and wastes by visually inspecting containers prior to collection. 
All collection boxes would be marked with "No Hazardous Materials" and company work orders 
would contain a prohibition against placement of hazardous materials or wastes in a Waste 
Resources Technologies container, a practice that is currently used at other company facilities. 

J-8) This comment concerns the proposed project, and does not address the adequacy or accuracy of 
the SEIR. For information, it is noted that, as stated on p. 37 of the SEIR, "[t]he majority of the 
Industry Group components would include a maritime component in their operations, and 
therefore would be considered maritime tenants of the Port." RMC Pacific, British Pacific 
Aggregates, and Mission Valley Rock would import raw materials by ship and barge, and ISG 
Resources is likely to use waterbome transportation in the future. In terms of public access to 
the waterfront, most of the Southern Waterfront is intended in the City's General Plan and the 
Port's Waterfront Land Use Plan to remain in maritime and industrial use, which generally limit 
opportunities for safe public access. No mitigation measures with regard to public access are 
required for the SEIR project. 

J-9) As stated on p. 59 of the SEIR, Phase I of the project (Industry Group components plus Illinois 
Street bridge) would not result in any parking shortfall attributed to the project. It is true, as 
stated by the commenters, that on-street parking availability is very limited in the area near 
Pier 70, although this is a function of activities and uses that exist at present, and would not be 



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VIII. SUMMARY OF COMMENTS AND RESPONSES 



C. WRITTEN COMMENTS AND RESPONSES 



exacerbated by Phase I of the project. Because there are no precise plans for Phase II - including 
development of industrial uses at Pier 70 and of the Pier 70 Mixed-Use Opportunity Area, there 
could be substantial additional parking demand, which would have to be addressed in future 
project-specific analyses. Review of development proposals for the Mixed-Use Opportunity 
Area, for which the Port will issue a separate Request for Proposals, would analyze parking 
supply and demand, and could also address other issues raised by the commenters, such as the 
potential for additional access to Pier 70. In addition, the Planning Department's Better 
Neighborhoods 2002 initiative will analyze other issues raised for the broader area, such as the 
development of additional transportation planning, including increased transit use and more 
bicycle routes. The commenters' suggestions regarding an extension of 22nd Street, 
development of bicycle and pedestrian paths, and development of a satellite parking facility 
could be considered in that context. However, with regard to the SEIR project, the SEIR 
identifies no significant transportation-related effects in the irmnediate Pier 70 area. However, 
the SEIR includes mitigation (Measure B.2, SEIR p. 145, and Measure C.4, SEIR p. 147) calling 
for the Port to develop a Transportation Systems Management Plan for future projects proposed 
at the Pier 70 Mixed-Use Opportunity Area and the Pier 90-94 backlands to reduce transportation 
and air quality impacts. 

J-10) Concerning potential noise impacts of the Waste Resources Technologies facility, it is very 
unlikely that operational noise would be apparent from nearby residential areas, particularly 
given the proposed new location for the operation, one fourth of a mile east of Illinois Street, or 
three times as far east of Illinois Street as the site described in the SEIR. Virtually all operations 
would be conducted indoors, lessening the potential for noise to travel. As for truck traffic, the 
volume of trucks would not be such that it would noticeably increase traffic noise, even on 
20th Street, where trucks would be concentrated. In addition, the Waste Resources Technologies 
operation would be subject to the San Francisco Noise Ordinance (Article 29 of the Police 
Code). 

J-1 1) Concerning controls on diesel engines, please see the discussion in the response to 
Comment H-14, p. C&R.48. 

Concerning air quality monitoring, such an effort would potentially be meaningful only for 
particulates, such as PM-10. Monitoring for concentrations of other pollutants, such as nitrogen 
oxides or reactive organic gases, would not be relevant because those pollutants are important 
not in themselves, but as ozone precursors that result in ozone formation only upon interaction in 
the atmosphere. Regarding PM-10 concentrations, the project includes numerous dust control 
measures, such as maintaining sufficient moisture content in stored aggregate, use of a filter on 
asphalt drum mixer(s) and installation of other best available control technology on stationary 
sources, and implementation of street sweeping and other ongoing dust control techniques 
around project components. These measures, assuming they are properly implemented, would 



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VIII. SUMMARY OF COMMENTS AND RESPONSES 

C. WRITTEN COMMENTS AND RESPONSES 

reduce potential particulate emissions. In addition, the Port routinely requires, as part of its 
tenant lease agreements, that tenants implement an ongoing dust mitigation monitoring problem. 

Routine monitoring, by contrast, would not do anything to reduce or eliminate particulate 
emissions. Furthermore, monitoring at one or more of the sensitive receptors identified in the 
SEIR would not allow for identification of the sources of particulates. Spot monitoring could be 
employed, at one or more potential sources of emissions - such as Industry Group component 
sites - as part of the Port's mitigation monitoring program, to ensure that project sponsors are 
complying with mitigation measures identified in the SEIR. Spot monitoring might also be used 
in the event that a problem is perceived; this might be an instance in which observation indicates 
that a mitigation measure is not being implemented or a complaint is received concerning dust. 

Issues such as tree planting are regularly considered as part of lease and development approval 
actions. While street trees can provide visual screening of industrial operations, they would be 
of limited benefit to air quality because they would not affect winds and air currents except at 
street level, whereas most major pollutant sources (exhaust stacks on industrial facilities and 
ships and even truck exhaust pipes) are at a greater height. Street trees could, however, provide 
incremental benefits with regard to roadside emissions. 

J- 12) The following is added as a new mitigation measure on p. 149 (and to p. S-32 in the Summary) 
of the SEIR: 

MEASURE IDENTIFIED IN THIS SEIR 

C.6 Consistent with the construction-period dust abatement program described in 
Mitigation Measure C.5, the Port shall require that Industry Group components 
and other aggregate-related tenants employ dust abatement procedures including, 
but not necessarily limited to, the following: 

• installation and operation of truck wheel-washing systems at plant exits for 
facilities that operate on unpaved surfaces; 

• daily street sweeping on streets surrounding aggregate-related facilities; and 

• clearly posting on the exterior wall or fence of such facilities a company 
telephone number for citizens to call with dust, noise, or other operational 
complaints, and designation of a Port staff contact for same. 

In addition, the following is added to the bulleted list of practices in Mitigation Measure D.2 on 
p. 149 (and p. S-33 in the Sunmiary) of the SEIR: 

• daily street sweeping of surrounding streets and, for facilities that operate on 
unpaved surfaces, installation and operation of truck wheel-washing systems 
at aggregate-related plants; 



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« 



Environmental Law and JusxrcE Clinic • School Of Law 



November 7, 2000 

Via Facsimile and First-Class Mail 

Environmental Review Officer 
San Francisco Planning Department 
1660 Mission Street, Suite 500 
San Francisco, CA 94103-2414 

Re: San Francisco Southem Waterfront Project - SAEJ Comments on Draft 
Supplemental Environmental Impact Report (Case No. 1999.377E) 

To Whom It May Concern: 

On behalf of the Southeast Alliance for Environmental Justice ("SAEP'). the 
Environmental Law and Justice Clinic ("ELJC") of Golden Gate University School of 
Law is pleased to submit the following comments on the Draft Supplemental 
Environmental Impact Report ("Draft SEIR") for the San Francisco Southem Waterfront 
Project ("Project"). These comments are submitted pursuant to CEQA' and are intended 
to supplement oral comments made by ELJC student clinician, Lynne Saxton, and by 
several representatives of SAEJ, all of whom appeared at the public hearing conducted by 
the San Francisco Planning Commission on October 26, 2000. 

I. INTRODUCTION 

The environmental impact report ("EIR"), with all its specificity and complexity, is the 
mechanism prescribed by CEQA to force informed decision making and to expose the 
decision making process to public scrutiny. Planning and Conservation League v. 
Department of Water Resources . 83 Cal. App. 4* 892 (2000); No Oil. Inc. v. Citv of Los 
Angeles . 13 Cal.3d 68,86 (1974). The EIR is, as the courts have said repeatedly, the "heart 
of CEQA,' " "an 'environmental "alarm bell," ' " and a "document of accountability." 
Planning and Conservation League . 83 Cal.App.4* at 910 {citing Laurel Heights 
Improvement Assoc. v. Regents of University of California . 47 Cal.3d 376, 392 (1988) 
("Laurel Heights")). Its purpose is to inform the public and its responsible officials of the 
environmental consequences of their decisions before they are made. Thus, the EIR 
protects not only the environment but also informed self-government. CEQA Guidelines 



' California Environmental Quality Act (CEQA), Pub. Resources Code Section 2 1 000 et 
seq., and the CEQA implementing regulations, known as "CEQA Guidelines", Cal. Code 
Regs., Tit. 14, Section 15000 et seq. 



Mailing Addrfss: 536 Mission Si rkf.i • S\n Frwcisco. CA • 94105-2968 
Offices at: 62 First Street. Si ite 240 • San Francis( (i. CA • Phone: i4l5) 442-664" • Fa\: (415) 896-2450 



RECEIVED 

NOV 9 2000 

PLANNING DEPT 



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§15003; Citizens of Goleta Valley v. Board of Supervisors . 52 Cal.3d 553, at 554 (1990); 
Laurel Heights . 47 Cal.Sd at 392; County of Invo v. Yortv. 32 Cal.App.3d 759, 180 
(1973). 



The Port of San Francisco ("Port") and City Planning Department are attempting to use a 
single CEQA environmental review document to serve multiple purposes. The Draft 
SEIR is intended to supplement the Waterfront Land Use Plan ("WLUP"), which is a 
"program EIR" certified by the Port in 1997. Furthermore, the Draft SEIR is intended to 
serve as a "project EIR" for several site-specific projects proposed by private entities 
seeking to lease property from the Port. Also, the Draft SEIR is to provide an 
environmental analysis of major Port projects, including construction of an inteimodal 
bridge and phased development of more than 100 acres of Port-managed land. During 
the scoping phase of the Project's environmental review process, ELJC submitted a letter 
to San Francisco Planning Department and characterized the Southern Waterfront EIR as 
an unusual, hybrid combination of a "program EIR" and "project EIR." We said that 
CEQA requires a full, detailed analysis of the Project's environmental impacts, and that 
the Draft SEIR should include an analysis of altematives for each individual site-specific 
project. See EL JC letter, dated July 12, 1999, incorporated herein by this reference. 

Unfortunately, the Draft SEIR fails in its objectives and purpose. The Draft SEIR does 
not provide an accurate, clear description of the Project and the environmental setting. It 
fails to properly analyze the Project's potential environmental impacts, particularly with 
regard to the traffic and air quality impacts caused by the Industry Group proposals. The 
Draft SEER also does not adequately identify and evaluate feasible mitigation measures 
and altematives to minimize the Project's significant impacts. Accordingly, the Pla nnin g 
Department and Port should reject the current Draft SEIR and prepare a complete, 
detailed EIR for the Project. 

II. DRAFT SEIR FAILS TO PROVIDE CLEAR PROJECT DESCRIPTION 

CEQA Guidelines Section 15124 requires certain information in the project description of 
EIRs, including "a general description of the project's technical, economical, and 
environmental characteristics, considering the principal engineering proposals if any and 
supporting public service facilities." See Coimtv of Invo v. City of Los Angeles. 71 
Cal.App.3d 185, 193 (1977)("An accurate, stable and finite project description is the sine 
qua non of an informative and legally sufficient EIR."). CEQA does not require technical 
perfection in an EIR, but rather adequacy, completeness, and a good-faith effort at fiill 
disclosure. CEQA Guidelines Section 15003(i). 

In the Draft SEIR, the Project is described as comprised of three categories of proposals: 
(1) six private entities' proposals, collectively referred to as the "Industry Group" 
components; (2) the Port's proposal to develop an intermodal rail and truck bridge over 
Islais Creek; and (3) the Port's fixture development projects. In reviewing the Draft SEIR, 
we found that the Industry Group proposals cover the following nine projects: 



2 



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1 . Bode Gravel's proposal to build an all-new ready-mix concrete facility, with an 
annual production of 500,000 cubic yards (one million tons) per year, at Pier 92. 

2. Mission Valley Rock's proposal to develop an aggregate import terminal at Pier 
92, next to Bode Gravel's concrete facility (amount of aggregate to be handled unknown). 

3. Mission Valley Rock's proposal to construct a new asphalt plant, with an annual 
production of 400,000 - 550,000 tons per year, at Pier 92. 

4. British Pacific Aggregates' (BP A) proposal to develop a storage facility for 
aggregate materials (sand, gravel and crushed stone), at Pier 94 (amount of aggregate to 
be handled unknown). 

5. BPA's proposal to construct a ready-mix concrete and/or asphalt plant at Pier 94 
(estimated 150,000 tons per year of each material). 

6. ISG's proposal to develop a "fly ash" storage facility using former grain silos, 
with an ultimate volume of 1 00,000 tons per year, at Pier 90. 

7. RMC Pacific Materials' proposal to develop a new ready-mix concrete facility, 
with an annual production of 325,000 - 425,000 cubic yards at Pier 80. 

8. Waste Resources Technologies' proposal to operate a constmction/demolition 
material recovery facility, which will handle an estimated 350 tons per day, at Pier 70. 

9. Coach USA's proposal to develop a bus storage, maintenance and repair facility, 
with 410 daily vehicle trips by buses, at Pier 96. 

Additionally, the Draft SEIR covers the following Port proposals: 

10. Port's proposal to develop the Illinois Street Intermodal Bridge across Islais 
Creek. 

1 1 . Port's proposal to increase cargo shipping at its container terminals, to handle 
200,000 TEU (20-foot equivalent units) of new cargo at Pier 80 and Piers 94-96. 

12. Port's proposal to increase the storage and drying of approximately 20,000 cubic 
yards of dredged materials annually at Pier 94. 

13. Port's proposal to develop approximately 100 acres of industrial, commercial, and 
residential projects at Pier 70, the "backlands" at Piers 90-94, and at the former Western 
Pacific rail yard. 



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In total, the Draft SEIR is intended to analyze the environmental impacts of thirteen 
separate proposals, all of which are considerably large and complex.^ However, the 
Draft SEIR does not provide an accurate and detailed Project description for many of the 
proposals. The type of information that would ordinarily be included in an EIR is 
omitted or incorrectly described. For the Industry Group proposals, the following 
information should be included: amount and types of throughputs for all equipment used 
to manufacture and store concrete, asphalt and aggregate materials; amount and types of 
ftiel use for combustion equipment; amount of concrete, asphalt and raw materials to be 
transported by tmcks and other mobile sources; amount of hauling capacity of trucks and 
other mobile sources; and an identification of processes that release pollutants to the 
environment, including all mobile and stationary sources of air pollution (criteria and 
toxic pollutants) and air pollution control equipment. The EIR should also identify the 
Industry Group's throughputs (production levels) as identified in their permits or permit 
applications, if available. 

The Draft SEIR does not clearly describe the amount of concrete, asphalt and aggregate 
materials that each facility will process and the maximum throughput levels established 
in their permits. For example, the project description in the Draft SEIR (p. 16) identifies 
RMC Pacific's future concrete production levels as 325,000 cubic yards in the immediate 
future, and 425,000 cubic yards by 2015. It also states that RMC Pacific would keep its 
existing plant at Third Street operational as a satellite facility, at about half of its capacity, 
for two years. 

Based on documents received by ELJC fi"om the Bay Area Air Quality Management 
District ("BAAQMD"), RMC's concrete mixer at its Third Street facility had a 
throughput of 396,800 tons in 1997 (equivalent to 198,400 cubic yards). Thus, the Draft 
SEIR indicates that RMC is planning to increase its 1997 concrete production levels by 
125,000 to 225,000 cubic yards. However, the impact analysis of the Draft SEIR fails to 
take into account this predicted increase in production and omits any information about 
the RMC plant doubling its current output (see p. 15-16). Also, Table A-1 in Appendix A 
identifies RMC Pacific's annual production level for concrete at 200,000 cubic yards and 
does not reveal the planned increases. This inconsistency is confusing and does not 
provide the clear and accurate information required by CEQA for informed decision 
making. 

Furthermore, the Draft SEIR is legally deficient because it does not provide a stable and 
finite description. It states that British Pacific Aggregates (BP A) is proposing to build a 
concrete and/or asphalt plant, which is supposedly covered by the Draft SEIR- The SEIR 



^ Last year, when the Planning Department issued the Notice of Preparation for the 
Project last year, there was no information provided on the asphalt plants proposed by 
Mission Valley Rock and British Pacific Aggregates. See EUC letter of May 12, 1999. 
The lack of notice and description regarding these facilities violates CEQA Guidelines 
Section 15082(a). 



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includes the BPA proposal, despite its vagueness and uncertainty. The SEIR does not 
analyze the impacts of the BPA concrete/asphalt plant proposal because it is assumed that 
BPA's production of these materials will shift production from other Industry Group 
facilities. See Draft SEIR, p. 13; A.3-A.4. Thus, the Draft SEIR is intended to serve as 
the CEQA document for a new industrial facility, but provides very little information 
about this proposal. The Draft SEIR's omission of ftmdamental information about the 
Project components prevents informed decision-making and informed public 
participation and undermines the purpose of the CEQA review process. (See also. 
Section IV below regarding deficiencies in SEIR's impact analysis.) 



m. DRAFT SEIR FAILS TO ACCURATELY DESCRIBE THE PROJECT'S 
ENVIRONMENTAL SETTING 



Section 15125 of the CEQA Guidelines provides, "An EIR must include a description of 
the physical environmental conditions in the vicinity of the project, as they exist at the 
time of the notice of preparation is published, or if no notice is published, at the time 
envirormiental analysis is commenced, from both a local and regional perspective. This 
environmental setting will normally constitute the baseline physical conditions by which 
a lead agency determines whether an environmental impact is significant. The 
description of the envirormiental setting shall be no longer than is necessary to an 
understanding of the significant effects of the proposed project and its alternatives.*' 

Chapter IH of the Draft SEIR describes the environmental setting and potential impacts of 
the Project. Since the Project is comprised of thirteen different proposals, the Project's 
envirormiental setting is described as including various vacant, undeveloped lands, vacant 
industrial buildings, and industrial/manufacturing buildings along the Southern 
Waterfront, extending from Pier 70 near 20th and Illinois Streets in the northem section 
of the Southem Waterfront area to Pier 96, near Cargo Way. : 

The Draft SEIR states that most of the Industry Group companies are currently located at 
existing sites in San Francisco, and would relocate to the Project area, and that two of the 
existing sites (Bode and RMC Pacific) are within the land use study area at Third and 
16th Streets and Third and Mariposa Streets, respectively. Draft SEIR, p. 37. This 
statement is misleading and should not be interpreted to mean that the Bode and RMC 
existing facilities are within the Project's environmental setting. The Southem 
Waterfront area was originally defined by the Port as extending tcom Piers 68-70 to India 
Basin. See Figure 1 of Draft EIR for Waterfront Land Use Plan (1997). The sites of the 
existing plants operated by Bode and RMC Pacific are located immediately north of the 
Southem Waterfront area, in a section referred to as South Beach/China Basin, which 
extends from Pier 22-1/2 to Mariposa Street (Pier 66). Bode and RMC Pacific must 
demolish their existing plants in the South Beach/ China Basin area as a result of the new 
Mission Bay development project and are seeking leases from the Port to build all new 
concrete facilities. Their relocation to the Southem Waterfront area would not be 
modification of existing projects, but a continuation and expansion of their businesses in 
a different environmental setting at new sites. Presumably, Bode and RMC's existing 



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facilities in the South Beach/China Basin area were not previously subjected to CEQA 
environmental review. These companies do not have any pre-existing rights or 
entitlements to cause environmental pollution on Port lands. Thus, they should not be 
deemed a part of the Project's physical environmental setting nor be used to establish the 
"baseline" for determining the significance of the Project's local impacts. See Benton v. 
Board of Supervisors . 226 Cal.App.3d 1467 (1991 ): Temecula Band of Luiseno Mission 
Indians v. Rancho California Water District . 43 Cal.App.4'' 425 (1996). 



rv. DRAFT SEIR FAILS TO ACCURATELY AND COMPLETELY 
ANALYZE THE PROJECT'S SIGNIFICANT ADVERSE IMPACTS 

A. Industry Group Proposal Impacts Should Be Evaluated Based on the Permitted 
Capacities, and Not Estimated Production Levels Based on a Market Demand Theory 

In evaluating the environmental impacts of the Industry Group proposals, the Draft SEIR 
assumes their facilities will operate at certain production levels, based on a prediction of 
future market demand, and this is used to identify traffic and air quality impacts. As 
discussed above in Section n of this letter, the Draft SEIR provides limited information 
with regard to the permitted throughputs and allowable production capacities of the 
Industry Group proposals for the concrete and asphah producing facilities. Instead, the 
Draft SEIR relies upon a market-based approach for determining production levels and 
these are used to calculate traffic and air pollution impacts for the short-term (2003) and 
long-term (2015). 

According to the Draft SEIR, the Planning Department, Port staff, and EIR consultants 
"reviewed current production volumes by local concrete-producing members of the 
Industry Group..,, along with the estimates and forecasts provided by the Industry Group, 
and determined that the production assumptions in this SEIR should be based on Industry 
Group consensus market estimate for near-term analysis. . . and the sum of the individual 
Industry Group members' production projections. . . should be the basis for the longer- 
range (cumulative) impacts. . Draft SEIR, p. A.1-A.2. The Draft SEIR claims that San 
Francisco is a relatively '"mature" market whose demand for concrete is more stable and 
"somewhat lower, on a per-person basis, than that of a rapidly growing conMnunity." 
Draft SEIR, p. A.3. 

This approach is flawed and violates the mandates of CEQA. The Draft SEIR does not 
provide any detailed information to evaluate the basis and reasonableness of the "Industry 
Group consensus market estimate." It is unclear what factors were considered in 
determining the future market for concrete and asphalt. The Draft SEIR refers to San 
Francisco's market as being stable, but may have ignored major development projects that 
are now imderway, including the Mission Bay project, redevelopment of the Hunters 
Point Shipyard and Mimi Light Rail System along Third Street. 



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The SEIR is misleading in that it claims the Industry Group's individual forecasts were 
used for long-term (2015) production predictions, while the Industry Group's consensus 
estimates of existing and near-term market demand was used for short-term (2003) 
production predictions. As discussed earlier, BPA's concrete and asphalt production is 
not included in the long-term production predictions (year 2015) and so the "worst case" 
scenario is never described in the Draft SEIR. Furthermore, the Draft SEIR contains 
inaccuracies in production calculations. We previously discussed the inconsistencies in 
the production levels for KMC Pacific; Appendix A uses 200,000 cubic yards while the 
project description indicates that RMC will produce up to 450,000 cubic yards by 2015. 

The Draft SEIR's use of a market demand approach for determining production levels 
and the Project's potential impacts does not give the community residents who will be 
most adversely affected by the Project any guarantees that the Industry Group companies 
will not increase their production levels if the market should increase. Unless the 
production levels are enforceable, there is nothing preventing the Industry Group 
companies fi-om expanding their operations to the maximum permitted levels (whatever 
that may be) and causing greater impacts than those analyzed in the Draft SEIR. 

Due to the adverse affect the Project will have on air quality and cumulative 
environmental impacts, the community should be informed of what will happen if the 
demand for concrete and asphalt increase, to be able to make informed and balanced 
decisions regarding the impact of the project on their community. Information about the 
maximum capacity or throughput for each pollution source of the Industry Group 
components is necessary for a proper evaluation of environmental impacts and health 
risks 



B. Local Impacts of Air Pollutants Will Be Greater 

The Draft SEIR underestimates the local impacts of the Project's emissions. For trucks 
traveling north, the local emissions calculations are based on trafGc within the project 
vicinity, using a maximum trip length of 3 miles (the average distance of the relocated 
concrete plants from Third Street at 16th Street and Mariposa Street to Third Street at 
Islais Creek). For trucks traveling south, no local emissions were added because it was 
assumed that this traffic was ah-eady in the immediate neighborhood of the project area. 
Draft SEIR p. 81. 

It is unclear whether the Draft SEIR separated out traffic generated by existing facihties 
versus new facilities. Also, the Draft SEIR does not reveal whether increased traffic 
along Third Street, from congestion and the construction of the Muni Light Rail line 
along Third Street, had been taken into account when calculating emissions of trucks 
idling at intersections or stopped by congestion. The Draft SEIR clearly indicates that the 
level of service (LOS) at various intersections in the project area would get worse through 
time. Furthermore, construction of the Muni Third Street light rail project is expected to 
remove one traffic lane in each direction along Third Street. It is reasonable to assume 



7 



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that these conditions would produce traffic delays and an increase in emissions generated 
by traffic heading southward. 

The Draf^ SEIR does not clearly reveal what assumptions were used to calculate PM-10 
emissions from stationary and mobile sources. The draf^ SEIR states that the maximimi 
daily emissions of reactive organic gases (ROG), nitrogen dioxide (NOx) and respirable 
particles (PM-10) from all project components combined would exceed the significance 
threshold of 80 pounds per day, and that the significance threshold for annual emissions 
would be exceeded for ROG and NOx, but not for PM-10 emissions. Pp .S-15; 84 (Table 
11). This assumes that the Bode and RMC projects do not increase their production 
levels. However, there is ah-eady evidence in the record that there may be significant 
increases in production - in the immediate future as well as long term. 

Also, the new asphalt facilities proposed by Mission Valley Rock and BPA most likely 
will generate significant PM-10 emissions. Two years ago, ELJC was involved in the 
CEQA environmental review process for the expansion and modemization of Beiiceley 
Asphalt Company's facility, located at 699 Virginia Street, Berkeley, CA, which 
increased its production capacity of "hot mix" asphalt concrete from 145,000 tons per 
year to 250,000 tons per year. The Berkeley Asphalt Company facility submitted permit 
applications to BAAQMD for various components, including a new baghouse and 
modified dryer, new low-Nox burner for dryer, new pug mill and ancillaries, new cyclone 
and two condensers, and new asphalt tank. BAAQMD determined that Berkeley Asphalt 
Company's increases in PM-10 emissions for the various facility components totaled 
more than 5 tons per year. 

In comparison, Mission Valley Rock is proposing to build an asphalt plant at Pier 92, 
with production levels at 400,000 tons per year in the near term and 550,000 tons by 
2015. Draft SEIR, p. 1 1. Mission Valley Rock's new asphalt facility is expected to 
produce 4 to 5 times the net increase of asphalt production that will be generated by 
Berkeley Asphalt Company's plant modemization and expansion efforts, but the Draft 
SEIR Appendix D (Table D-4) claims that the PM-10 emissions at Mission Valley 
Rock's plant will be 0.00 for PM-10 comb, and 1.12 tons/year of PM-10 dust. The SEIR 
does not reveal its net emissions calculations in Appendix D. We question their 
reasonableness and require additional information in order to fully evaluate this analysis. 

C. Draft SEIR's analysis of the Project's Cumulative Impacts is Incomplete 

The Draft SEIR fails to recognize that the Bayview-Hunters Point community, a 
predominantly African- American neighborhood, has been disproportionately burdened by 
pollution and its residents have repeatedly raised enviroiunental justice and public health 
concerns to the Port and San Francisco Planning Department. The Draft SEIR does not 
adequately describe the major emitting facilities already existing in or near the Project 
area; this deficiency is found in the Draft SEIR's discussion on land uses in the vicinity 
(p. 27); air quality impacts (p. 77), and cumulative air quality impacts (pp. 96-98). 



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The Draft SEIR does discuss, albeit briefly, the proposed expansion of the Southern 
Energy's Potrero power plant, (pp. 29, 97). It mentions that the expected closing of 
Hunters Point power plant is contingent upon the City having a reliable source of energy. 
But the Draft SEER, does not consider the likelihood of both power plants operating, 
rather than one expanding and the other closing, and fails to analyze the cumulative 
impacts of the Project if both power plants are operating. Given the current problems 
with electrical industry deregulation in California, it is reasonable to expect that the 
California Independent System Operator will not allow the Himters Point Power Plant to 
shutdown while there is an "energy crises" and reported shortage of electrical generation 
resources. 



In the air quality analysis, in the section entitled, '"Existing Emissions Within Project 
Vicinity," the Draft SEIR provides only a very brief description of existing emissions and 
limited the discussion to three sentences: 



"Existing emissions sources within the project vicinity include 
large stationary sources, such as the Potrero and Hunters Point 
power plants, and other stationary sources, as well a (sic) mobile 
sources. The smaller stationary sources in the area, such as paint 
shops and small boilers, emit quantities of emissions that are 
substantially less than the mobile sources and the power plants. 
Mobile sources include autos and trucks traveling on Interstate 
280, located approximately one mile west of the project site, and 
auto and trucks traveling on nearby Third Street and other local 
streets." Draft SEIR, p. 77. 

This discussion does not adequately describe the numerous major pollution sources in the 
Bayview-Hunters Point commimity. We have previously informed the Plarming 
Department of the neighborhood pollution sources and public health concerns. In 
ELJC's earlier comment letter, dated July 12, 1999, submitted for the scoping process for 
the Southem Waterfront Supplemental EIR, we described the project setting, outlined the 
envirormiental justice and public health concerns, and included a list of toxic emission 
sources (Exhibit B attached thereto). 



Some of this information was only briefly mentioned in the Draft SEIR's discussion of 
sensitive receptors (see Draft SEIR, p.77-78). In the SEIR's discussion of the 1997 
hospitalization study conducted by physicians from the San Francisco Department of 
Public Health and the University of California at San Francisco, the Draft SEIR states, 
"The study did not evaluate the cause(s) of the observed higher rates of these ailments, 
and no inferences can be made regarding the relationships between industrial emission, 
mobile emissions, other sources, and health problems in the area." For the Draft SEIR to 
claim that "no inferences can be made" between industrial emissions, mobile emissions, 
and health impacts is not only inaccurate, it minimizes the Project's potential significant 
envirormiental and health impacts of the Project on the Bayview-Hunters Point residents. 
The mischaracterization of the potential health impacts runs counter to the very purpose 



9 



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of CEQA, which is to inform the public and agency decision makers about the significant 
impacts of a project. The health concerns of community residents need to be addressed in 
light of the significant adverse cumulative effects of localized particulate emissions and 
diesel particulate emissions (see Draft SEIR, p. 96). 

Furthermore, this "no inference" statement on p. 78 of the Draft SEIR is inconsistent with 
public health information which was previously provided to the Planning Department. 
See EUC's letter to Port and Planning Department, dated May 1, 1998, submitted in 
connection with the environmental review of Port leases for Piers 90-92 and Pier 96 
(relating to the Norcal Waste System's interim lease), page 6. See also, ELJCs letter to 
Planning Department, dated July 12, 1999 (comments for Project scoping phase), page 5. 

We believe that the Draft SEIR is misleading in its omissions regarding the 
environmental and public health concems of the local neighborhood. Without accurately 
describing the immediate neighborhood of the Project, the Draft SEIR fails to recognize 
the context and significance of the Project's effects. The SEIR recognizes that the Project 
will cause significant impacts in traffic and air pollution, and these impacts are not 
minimized or eliminated by the proposed mitigation measures. The Project will clearly 
contribute to the disproportionate impacts burdening the Hunters Point community and 
this implicates Title VI of the Civil Rights Act. The Draft SEIR should carefully analyze 
the Project's cumulative impacts that would burden the surrounding community and the 
SEIR's failure to do so undermines the purpose and policies of the CEQA review process. 
"The purpose of CEQA is not to generate paper, but to compel government at all levels to 
make decisions with environmental consequences in mind." CEQA Guideline 
§ 15003(g); Bozune v. LAFCO . 13 Cal. 3d 263 (1975). 



IV. DRAFT SEIR FAILS TO ADEQUATELY CONSIDER FEASIBLE 
MITIGATION MEASURES 



The mitigation measures identified in this SEIR are inadequate, as they do not address the 
most severe environmental effects of the Project. Section 15126.4 of the CEQA 
Guidelines requires EIRs to describe feasible mitigation measures that could minimize 
significant adverse impacts. The description must identify mitigation measures or 
alternatives for each significant environmental effect identified in the EIR. CEQA 
Guidelines Section 15126.4(a)(1). The mitigation measures must be fiilly enforceable 
through permit conditions, agreements or other legally-binding instruments. CEQA 
Guidelines Section 1 5 126.4(a)(2). 

The Project will have significant adverse impacts on regional air quality. For example, 
the Project's NOx emissions will exceed BAAQMD's daily significance threshold by 
roughly 25 times m both 2003 and 2015. SEIR, p. 84. Both stationary and mobile 
sources contribute to the degradation of regional air quality, with the most emissions 
coming fi-om ship and rail. SEIR p. 84. The only mitigation measures identified in the 
SEIR for stationary sources are the implementation of B ACT technology. However, 



10 



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Anne Eng and Lynne Saxton 
Environmental Law and Justice Clinic 

BACT technology iSWi'i^Mmm^.^Y^Msion reductions resulting from 
BACT technology is not onlyre^fiff^!)^'l2(J9%iit was already assumed in the SEIR 
when calculating air quality impacts. Also, there are no mitigation measures explored in 
the SEIR to reduce pollution &o&^p Ma rail. The Port could explore working with its 
potential tenants to import raw materials on barges using clean-fiieled tug boats, or to use 
low-emissions equipment to transfer aggregate materials at or between facilities. 

CEQA establishes a duty for public agencies to avoid or minimize environmental damage 
where feasible, and agencies are required to give major consideration to preventing 
environmental damage. CEQA Guideline § 15021(a)(1). One of the policies governing 
CEQA is to prevent significant, avoidable damage to the environment by requiring 
changes in projects through the use of alternatives or mitigation measures when the 
governmental agency finds the changes to be feasible. CEQA Guideline § 15002(a)(3). 
This Project will have severe impacts on air quality. To comply with CEQA, the adverse 
effects need to be either mitigated or alternatives need to be adopted. 

VI. DRAFT SEIR FAILS TO ADEQUATELY CONSIDER ALTERNATIVES 
TO THE PROPOSED PROJECT 



Section 15126.6 of the CEQA Guidelines requires EIRs to describe a range of reasonable 
alternatives to the project, or to the location of the project, which would feasibly attain 
most of the basic objectives of the project but would avoid or substantially lessen any of 
the significant effects of the project. Under CEQA, the project proponent must focus on 
alternatives that reduce the environmental effects to a level of insignificance even if they 
are more costly or they impede the project's objectives to some degree. CEQA 
Guidelines Section 15126(d)(3). 

In ELJC's letter of July 12, 1999, we stated that CEQA requires a careful examination of 
alternatives for each site-specific project. This was not done. Instead, the Draft SEIR 
provided 3 alternatives for the entire Project (a No Project altemative, a Reduced Scale 
alternative and a Residential Use Future Scenario). ELJC and SAEJ appreciate the Port 
and Planning Department's consideration of these altematives, especially the Reduced 
Scale altemative which would not include several major polluting sources, such as the 
Mission Valley Rock's proposal for an asphalt plant and the BPA's proposal for future 
concrete and asphalt plants. However, this range of altematives is inadequate given the 
scope and significant impacts associated with several components of the Project. See Al 
La rson Boat Shop. Inc. v. Board of Harbor Commissioners. 18 Cal.App.4* 729 (1993). 

In conclusion, we believe that the Draft SEIR fails to meet several fundamental 
requirements of CEQA and should be rejected. The Project's components should be 
carefully re-evaluated and their impacts fully disclosed. 



S^ely, 
Anne Eng 




ynne Saxton 



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VIII. SUMMARY OF COMMENTS AND RESPONSES 

C. WRITTEN COMMENTS AND RESPONSES 

LETTER K - ENVIRONMENTAL LAW AND JUSTICE CLINIC, GOLDEN GATE 
UNIVERSITY LAW SCHOOL 

K-1) In the SEIR's near-term (up to 2003) analysis, neither the permitted nor physical capacities of 
the Industry Group facilities were considered the appropriate measure of total Industry Group 
production, because an increase in the supply of construction materials is more likely to be a 
result of, rather than a cause of, increased development activity. That is, the amount of 
development activity would be expected to generate a demand for concrete and asphalt less than 
the physical design capacity of the proposed Industry Group facilities. Accordingly, as described 
in Appendix A of the SEIR, the analysis of aggregate-related impacts is based on an overall 
production volume that is assumed to be generated by the market for construction materials. In 
other words, the assumptions underlying the traffic and air quality analyses are less dependent on 
which Industry Group member imports, produces, or distributes a specific quantity of material 
than on the total Industry Group "throughput," or quantity of material processed. It was for this 
reason that, as described in SEIR Appendix A, the SEIR analysis of near-term impacts relied on 
the consensus of the Industry Group's market projections for ready-mix concrete and asphalt 
concrete consumption, which is based on existing demand. As stated in Appendix A: 

The Industry Group estimate of the market for ready-mix concrete and asphalt is 
based on current demand for these construction materials in San Francisco and 

nearby communities It should be noted that the ready-mix concrete 

industry typically develops forecasts of market demand based on population and 
that, while economic activity may have short-term effects on production (for 
example, demand for concrete in San Francisco is relatively high at present due to 
the large amount of building activity; similarly, demand was relatively low during 
the early 1990s due to the recession), over time the volume of concrete used is 
largely a function of the overall growth in population. Therefore, as a largely 
built out location, San Francisco is considered a relatively "mature" market 
whose demand for concrete is more stable and somewhat lower, on a per-person 
basis, than that of a rapidly growing community. 

As also stated in Appendix A, the SEIR cumulative analysis (2015) assumed greater throughput, 
based on the sum of individual Industry Group members' forecasts, even though the total was 
greater than market conditions might support because these individual forecasts projected that 
one or more producers would increase their share of the ready-mix or asphalt concrete markets, 
even though the market demand would not necessarily increase. 

Regarding the commenters' suggestion that it was inappropriate to treat several project 
components as a single project for purposes of CEQA review, as stated in the response to 
Conmient H-10, p. C&R.44, concerning the SEIR's air quality analysis, the aggregate-related 
Industry Group project components would, to a great extent, constitute a closed system; that is. 



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aggregate and cement would be imported via ship, truck, or rail by one Industry Group 
component and then be delivered via truck or conveyor to a second component for processing 
and then delivery by truck to a user. In addition, given that ready-mix concrete and asphalt 
concrete are normally produced close to the point of use, owing to the weight and the limited 
working time of the finished material, the Industry Group members would essentially serve the 
same market for construction materials. Because of this interrelationship among the aggregate- 
related entities, analysis of each of them singly would have failed to capture the true impacts 
resulting from the shipment and transfer of materials between the project components. 
Furthermore, the SEIR describes both the physical improvements proposed as part of each 
component and the assumptions regarding production volumes (throughput) on which the traffic 
and air quality analyses are based, and therefore the SEIR provides a fully adequate project 
description. The Planning Department made a decision to include the two other (non-aggregate) 
Industry Group components - Waste Resources Technologies and Coach USA - in the SEIR 
project description in light of their proposed location in the Southern Waterfront area. Each of 
these components is similarly described in terms of proposed improvements and traffic 
assumptions. The final component of Phase I of the project, the Illinois Street Intermodal 
Bridge, was included in the SEIR because it would be integral to the transportation network that 
would serve the Industry Group project components and the other maritime and industrial traffic 
in the Southern Waterfront. 

As for Future Port Development (Phase II of the SEIR project), the description is necessarily less 
detailed. A major component of this phase, the Pier 70 Mixed-Use Opportunity Area, will be the 
subject of a separate Request for Proposals by the Port in 2001, with appropriate additional 
CEQA review as required once that component is more fully defined. The other largest 
component of Phase II, the Pier 90-94 backlands, is almost all designated in the Port's 
Waterfront Land Use Plan for future maritime uses. Thus, the development assumptions used in 
the SEIR analyses would entail major changes in the planning framework and in land uses. The 
Port plans further study to determine whether non-maritime use is feasible on the Pier 90-94 
backlands; the SEIR assumed office and/or research and development uses to provide a general 
understanding of environmental impacts at a very conceptual level, to inform the planning study 
for this area. 

The figures included on page 3 of the comment letter reflect either proposed plant capacities (as 
given in SEIR Chapter II, Project Description, in the text descriptions of each component) or 
individual Industry Group projections (as provided in Table A-1 of SEIR Appendix A), but they 
do not conform with the more important set of numbers that formed the basis for the SEIR 
analysis, which are shown in Table A-2 of Appendix A. Thus, for example, the production 
volume cited by the commenters for RMC Pacific, on page 4 of the comment letter, is accounted 
for as part of the overall production of ready-mix concrete (650,000 cubic yards in the near term, 
of which half would be produced by RMC Pacific and half by Bode, and 800,000 cubic yards in 



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the long term, again of which half would be produced by RMC Pacific and half by Bode^). For 
the SEIR analysis, however, the specific production volume by RMC Pacific is less important 
than the overall Industry Group throughput, and the SEIR acknowledges that production volumes 
for individual Industry Group components could shift among the components without affecting 
the overall analysis. Similarly, as stated on SEIR p. 13, if British Pacific Aggregates (BPA; now 
Hanson Aggregates) were to obtain approval for and begin production of ready-mix concrete or 
asphalt, the SEIR assumes that such production would result in a decrease in other Industry 
Group member(s)' production, compared to near-term production volumes assumed in the SEIR: 

Production of ready-mix concrete and/or asphalt by BPA would be contingent on 
the company capturing a share of the local market for one or both products. As 
described in Appendix A, this SEIR does not assume that BPA would engage in 
production of either product, (emphasis added) However, as also stated in 
Appendix A, the net result of BPA producing either or both of these materials 
would not be an increase in the total volume of concrete or asphalt manufactured 
within the Southern Waterfront area, but an incremental shift in the location of 
such production. 

As indicated in SEIR Table A-1, British Pacific Aggregates' individual production estimate was 
included in the total volumes of ready-mix concrete and asphalt concrete included in the long- 
term (2015) analysis in the SEIR. However, the entire volume of asphalt production was 
assigned to Mission Valley Rock for purposes of the SEIR analysis because Mission Valley 
Rock is further advanced in planning its proposed asphalt plant, while BPA (now Hanson 
Aggregates) is less certain about its proposed asphalt plant. Therefore, the SEIR analysis, which 
is based on overall throughput, would remain valid if BPA were to obtain approval for concrete 
or asphalt production. 

Most of the specific information that the commenters state on page 4 of their letter is not 
included in the SEIR is included in Appendix A for the Industry Group as a whole, including 
throughput volumes, origin of materials, and the means of transportation. Proposed air pollution 
control equipment is described in SEIR Section III.C, Air Quality (see p. 91), and this section 
also describes equipment, such as the asphalt drum mixer, where asphalt cement would be mixed 
with aggregate to create asphalt concrete. Other information, such as the amount and type of 
(diesel) fuel use, are not specifically provided but are implicit in the calculations of emissions of 
criteria air pollutants and diesel particulate. A haul truck capacity of 25 tons, and a cement 
mixer capacity of 9 cubic yards (18 tons), and an asphalt concrete truck capacity of 22 tons were 
assumed in both the traffic and air quality analyses. 



These volumes are exclusive of the ready-mix concrete production by existing small producers'in the project area. 



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Vm. SUMMARY OF COMMENTS AND RESPONSES 

C. WRITTEN COMMENTS AND RESPONSES 

Concerning the Notice of Preparation for the SEIR, the NOP issued by the Planning Department, 
dated June 12, 1999, includes the following text: 

British Pacific Aggregates: bulk cargo and asphalt batching plant use at a 
Pier 94-96 location, requiring about 436,000 sf of land. 

Although the Mission Valley Rock project component was not described in the NOP as including 
asphalt production, as described above, the SEIR analyses were based on assumptions of overall 
Industry Group production for both concrete and asphalt. As with concrete, the SEIR does not 
assume that British Pacific will produce asphalt; rather the asphalt production is assigned, for 
analysis purposes, to Mission Valley Rock. As discussed above, production of asphalt by BPA 
(now Hanson Aggregates) would be contingent on that company capturing a share of the local 
market, and would not increase overall production in the project area, but rather reallocate the 
total volume of asphalt produced. 

To more clearly link the SEIR production assumptions to lease conditions, the Port has agreed to 
include the following mitigation measure as part of the project. This measure is added to the end 
of SEIR p. 147 (and to p. S-31 in the Sunmiary): 

C.4A To regulate the production of concrete or asphalt material consistent with the 
volumes analyzed in the Southern Waterfront SEIR, any lease for concrete or 
asphalt batching operations on Port property shall include a provision setting 
forth the maximum production volume allowed under the lease, such that the 
cumulative total of production volumes of such batching operation leases shall 
not exceed the volumes assumed and analyzed in the SEIR. 

To monitor production volumes that may occur on Port property, the Port shall 
require as a condition of each lease that each tenant provide annually an audited 
account of the concrete and/or asphalt production volumes provided by each 
concrete or asphalt production business. The Port shall incorporate this 
information in an annual report to the Port Commission. 

Should any existing tenants propose to increase production above the amounts 
stipulated in the lease, such change would require an amendment to the lease, 
and would be subject to further environmental review by the San Francisco 
Planning Department's Major Environmental Assessment (MEA) division. In 
determining whether further environmental impact analysis will be required, 
MEA will consider the production levels cited in the Port's report and any 
emission-reducing improvements that may have been incorporated into the on- 
site operations (stationary sources), and trucks and other vehicles associated with 
the operations (mobile sources). 

K-2) As stated on p. 47 of the SEIR, although a large number of vehicle trips related to the Industry 

Group project components are currently being made, under existing conditions, to and from other 



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parts of San Francisco (including those to and from Bode and RMC Pacific), these existing trips 
were not "backed out" of the traffic analysis because many of these trips originate at the fringe of 
or outside the study area and thus may not travel through most of the analysis intersections. The 
result, as stated on SEIR p. 47, is that the traffic analysis is conservative. With regard to the air 
quality analysis, emissions resulting from existing activities, including traffic to and from the 
Bode and RMC Pacific sites, were properly discounted from the analysis of regional emissions, 
because the area of analysis encompasses the entire Bay Area Air Basin. However, for the 
analysis of local emissions, most existing emissions (except those occurring within three miles of 
the new sites) were not deducted from the project totals, because, as stated on SEIR p. 81, the 
relocation of existing facilities would increase emissions at the new locations, even if the effect 
on regional emissions would be negligible. Regarding the two legal decisions cited by the 
commenters, neither is applicable to the proposed project: in both cases, the question was 
whether, for a proposed modification of an approved but unbuilt project, only the incremental 
change need be analyzed. Both cases upheld the use of a Negative Declaration for purposes of 
environmental review of the incremental change of a project previously approved but not built. 
Neither of these cases support the notion that only conditions subject to previous CEQA analysis 
should be included in the existing setting. On the contrary, CEQA Guidelines Section 15125 
states, "An EIR must include a description of the physical environmental conditions in the 
vicinity of the project, as they exist at the time the notice of preparation is published. . . 
Because both the Bode and RMC Pacific facilities are in existence, and were at the time the 
Notice of Preparation was published, these facilities are properly considered as part of the 
existing setting, and the discontinuation of operations at these facilities and commencement of 
operations by Bode and RMC Pacific at new plants within the project area is all properly 
considered as part of the project analyzed in the SEIR. 

K-3) As described in SEIR Appendix A, the Industry Group's market-based consensus forecast was 
used for the near-term analysis, while the sum of the individual Industry Group members' 
projections was used in the long-term analysis, resulting in a substantially greater volume of both 
ready-mix concrete and asphalt concrete being assumed to be produced by 2015. This 
conservative approach was taken precisely to capture potential worst-case effects, despite 
information presented by the Industry Group indicating that the SEIR's 2015 production 
forecasts were unrealistically high. 

Regarding the potential for British Pacific Aggregates (now Hanson Aggregates) to produce 
ready-mix concrete and asphalt concrete, as stated in the response to Comment K-1, above, 
British Pacific Aggregates' individual production estimate was included in the total volumes of 
ready-mix concrete and asphalt concrete included in the long-term (2015) analysis in the SEIR, 
as indicated in Table A-1 of SEIR Appendix A.. 

Please see also the response to Comment K-1, above. 



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Vm. SUMMARY OF COMMENTS AND RESPONSES 



C. WRITTEN COMMENTS AND RESPONSES 



K-4) Please see the response to Comment K-2, above, concerning traffic from existing facilities, 
which was not removed from the analysis (with the exception of 84 daily truck trips hauling 
dredge sand from Pier 92 to Bode and RMC's existing plants on Third Street; see SEIR Tables 2 
and 3, pp. 50 and 51). 

As stated on SEIR p. 47, the transportation analysis accounts for not only implementation of the 
Third Street light rail line (with its accompanying changes in lane geometry along Third Street), 
but also additional background, or cumulative, traffic growth due to the Mission Bay project and 
redevelopment of Hunters Point shipyard and the larger Bay view-Hunters Point neighborhood. 
In terms of emissions of trucks, buses, and automobiles, the air quality analysis was derived 
directly from the traffic analysis, and therefore included the same assumptions regarding 
cumulative growth. 

K-5) The commenters are correct in noting that the near-term (2003) emissions inventory presented in 
SEIR Table 1 1 do not assume increased production volumes of ready-mix concrete. However, as 
described in SEIR Appendix A, an increase is assumed by 2015. 

Regarding emissions from the proposed asphalt plant, as stated in Appendix D of the SEIR, 
emissions factors were taken from the U.S. Environmental Protection Agency publication 
Compilation of Air Pollutant Emission Factors (Fifth Edition), which is commonly referred to as 
"AP-42." The factor used was 0.0045 pounds of PM-10 emitted per ton of material processed. 
This is the rate from the 1995 version of AP-42 for "filterable" PM-10, assuming a natural-gas 
fired drum mixer and the use of a fabric filter, as would be used at the proposed Mission Valley 
Rock plant.^'^ A key distinguishing factor between the proposed Mission Valley Rock plant and 
the existing Berkeley Asphalt plant is that the new plant would employ a counter-flow drum 
mixer, which, as stated on SEIR p. 95, "prevents direct contact between the material being mixed 
and the hot exhaust gases in the dryer." The existing Berkeley Asphalt plant is a batch mix plant, 
which has a different type of mixing process. The comparable AP-42 emissions factor for 
filterable PM-10 for a batch plant with fabric filter is 0.016 pounds per ton of material processed, 
or more than 3.5 times the rate for a drum mix plant. This different rate accounts for a 
substantial portion of the difference in the emissions between the two plants. 

In addition, a review of calculations prepared by the Bay Area Air Quality Management District 
in connection with the permit applications for the expansion of the Berkeley Asphalt plant that is 
discussed by the commenters indicates that PM-10 emissions were assumed to increase by a 



This rate does not include "condensable" PM-10 (particulates that are in gaseous form when they are emitted from the 
exhaust stack but condense into small particles upon cooling), because actual testing of stack emissions from a similar plant 
indicates that condensable particulate emissions are negligible. 

On December 22, 2000, EPA published revised PM-10 emission factors for the drum mixer of an asphalt plant. The new 
emissions rate of 0.0039 pounds per ton of material processed is lower than the rate used in the SEIR. indicating that the 
SEIR analysis is conservative. 



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factor of 7.5. from slightly less than one ton to 7.3 tons, because the calculations assumed 
maximum hourly production would occur for 10 hours per day, 6 days per week, throughout the 
year. The net result w ould be an annual production volume of 1 million tons, or four times the 
amount that Berkeley Asphalt proposed in its application to the BAAQMD. This would not be 
realistic. Furthermore, the existing emissions were based on actual then-recent throughput, not 
the then-permitted 125,000 tons per year. Therefore, the BAAQMD calculations, while intended 
to demonstrate the maximum potential increase, are not relevant to the SEIR's analysis of 
potential impacts at the asphalt plant proposed for the Southern Waterfront. 

K-6) The SEIR adequately describes both the setting and potential cumulative effects with regard to 
air quality. Preparation of an inventory of existing emissions (i.e.. the number of pounds of 
various criteria pollutants emitted within a particular area) is beyond the scope of any EIR. and is 
not necessary in order to evaluate a project's impact on the airshed. As described in the SEIR 
(pp. 78-79), such evaluation is performed by comparing the project's emissions with the 
significance criteria promulgated by the Bay Area Air Quality Management District of 
80 pounds per day or 15 tons per year for reactive organic gases (ROG), nitrogen oxides (NO^), 
and respirable particulate matter (PM-10). The SEIR (p. 83) concludes that these criteria would 
be exceeded on a daily basis in both 2003 and 2015, and that the annual criteria would also be 
exceeded for ROG and NO^ in each analysis year, and that the project impact would therefore be 
significant. 

However, the commenters' concerns are principally with regard to local impacts from sources in 
the vicinity of the SEIR project area. The SEIR evaluates local air quality effects for carbon 
monoxide and, in recognition of the concentration of industrial uses proposed, and the 
anticipated corresponding concentration of truck traffic, for PM-10 and diesel particulate matter. 
As stated on SEIR p. 78, "because of the location and concentration of uses proposed by 
members of the Industry Group and the sensitivity of nearby populations, this SEIR goes well 
beyond the typical level of air quality analysis in EIRs to address potential health effects of 
localized air pollution." As described on SEIR p. 91, the local impact analysis involved 
modeling of pollutant concentrations (i.e., how much PM-10 is contained within a given volume 
of air) and evaluating the results against health-based standards to determine if emissions 
generated by the project would result in enough of a concentration of carbon monoxide, PM-10, 
or diesel particulate matter so as to create concern regarding localized health effects. The SEIR 
determined that no project-specific significant effect would occur, because concentrations would 
not exceed the applicable standards (see SEIR Tables 16, 17, and 18, pp. 90. 94, and 95). Note 
that Table 17 is revised herein and is presented above. 

As noted in the SEIR, and remarked upon by the commenters, there are numerous emissions 
sources in the project area vicinity, many of which were identified in the commenters' letter in 
response to the SEIR Notice of Preparation (NOP). As characterized in the SEIR, and 



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C. WRITTEN COMMENTS AND RESPONSES 

corroborated by the list of B AAQMD-permitted facilities submitted with the commenters' NOP 
response, most potential emissions sources are relatively small facilities, such as dry cleaners, 
auto body, paint, and repair shops, gasoline stations, and printing shops. The list also includes 
food and furnishing producers. Most of these sources generate little in the way of particulate 
matter and, while they may emit other pollutants, there is no reliable and measurable way of 
adding those emissions to project-generated particulate emissions and producing an intelligible 
result. Thus, characterizing emissions from all existing sources would require a great effort that 
would yield limited results, because the majority of sources would have little or no effect on 
PM 10 or diesel particulate concentrations at locations where project sources (Industry Group 
components) would have the greatest effect. Nevertheless, in light of existing and potential 
future particulate emissions from certain key non-project sources, such as increased vehicle and 
truck traffic and the planned expansion of Southern Energy's Potrero Power Plant, the SEIR did 
conclude that "cumulative concentrations of PM-10 and diesel particulate experienced locally, 
while unknown because of the wide array of sources in the existing environment, could exceed 
significance thresholds . . . [and that, because] the project would add some increment to existing 
local PM-10 and diesel emissions, . . . these emissions are deemed cumulatively significant, 
although the project itself would not have a significant effect with regard to local concentrations 
of PM-10 or diesel particulate" (SEIR pp. 97-98). 

Concerning existing and future public health concerns in the project area, it is not the intent of 
the SEIR authors to minimize concerns in local communities, particularly the Bayview-Hunters 
Point neighborhood, about local health conditions. It was precisely for this reason that the recent 
study conducted in the area is described on SEIR pp. 77 and 78. However, after consultation 
with the San Francisco Department of Public Health, the SEIR authors noted that the 1997 
hospitalization study did not attempt to establish any cause-and-effect relationship between 
emissions sources and hospitalization rates. 

K-7) All of the mitigation measures described in the SEIR are fully enforceable, through inclusion in 
lease documents (or future development agreements) with the Port, through existing permit 
procedures, or by means of actions that could be taken by the Port or other City agencies. 

Concerning ship and rail emissions, as stated in the SEIR on p. 70, there is no local authority to 
require reductions in ship or rail emissions, which are solely within the purview of the U.S. EPA. 
It is noted that the EPA plans to propose standards by 2002 limiting the amount of NOx 
emissions from marine diesel engines in U.S. waters. 

K-8) CEQA requires analysis of alternatives that "would feasibly attain most of the basic objectives of 
the project but would avoid or substantially lessen any of the significant effects of the project" 
(State CEQA Guidelines Sec. 15126.6). The SEIR states, on p. 167: 



Case No. 1999.377E 



C&R.102 

ESA 990267 



Southern Waterfront SEIR 



VIII. SUMMARY OF COMMENTS AND RESPONSES 



C. WRITTEN COMMENTS AND RESPONSES 



San Francisco has a limited supply of industrially zoned land that could 
accommodate components of the project such as the Industry Group uses, and 
also has a limited supply of land that can acconnmodate both marine and rail 
transport. This supply of land is located entirely within the southeastern quadrant 
of the City, and thus the [Planning Department and the Port] concluded that even 
if an alternative site could be identified, its use would not eliminate significant 
impacts associated with the project. For example, traffic impacts of project uses 
would likely affect many of the same intersections examined in this SEIR, and 
particularly those where significant unavoidable effects were identified, because 
those intersections are along key routes through the southeastern portion of 
San Francisco. With regard to air quality, the project's significant unmitigable 
effects would occur with regard to regional air quality, and would therefore be 
little affected by a shift to other site(s). 

As described beginning on SEIR p. 3, the Port of San Francisco's primary objective for the 
project is "to maintain and expand cargo shipping and maritime businesses at its existing 
terminals at Piers 80, 90-92, and 94-96 on the north and south sides of Islais Creek east of the 
existing Third Street Bridge, and the existing ship repair yard at Pier 70." Another objective is 
construction of a rail and truck access bridge over Islais Creek, between the two cargo terminals, 
to increase efficiency and marketability of the terminals. Secondary objectives include 
diversification of marketing efforts to increase cargo terminals usage; increased productivity of 
Port assets through interim use of maritime expansion land; and development of beneficial non- 
maritime land uses that are compatible with maritime activities in areas surplus to long-term 
maritime needs. For the Industry Group, a primary objective is "to meet the continuing demand 
for construction materials." Other objectives include retention of existing ready-mix concrete 
production in the City and introduction of asphalt production to meet local demand; retention of 
uses being displaced by development; facilitate ship-borne import of construction aggregates; 
co-location of compatible aggregate-related uses; retain and increase employment; and operation 
of a construction/demolition material recovery facility. 

Necessarily, the overriding objectives of maintenance and expansion of cargo shipping can only 
be achieved in the area from Pier 80 through Piers 94-96, which contains the Port's primary 
cargo facilities. However, it is also the cargo shipping activity - both Industry Group and other 
shipping - that would result in the greatest share of significant unavoidable effects - those 
related to Air Quality. As described in SEIR Chapter V, these project effects are regional, in that 
they are a result of the amount of each of the three key criteria air pollutants that would be 
emitted in the Bay Area Air Basin. Locally, the project effect would not be significant, as 
explained on SEIR pp. 89-96, although the project would contribute to a cumulative significant 
effect on local air quality. Again, however, it would be shipping that would cause the greatest 
share of the effect. 



Case No. 1 999. 3 77 E 



C&R.103 

ESA 990267 



Southern Waterfront SEIR 



Vm. SUMMARY OF COMMENTS AND RESPONSES 



C. WRITTEN COMMENTS AND RESPONSES 



Alternative locations for one or more of the aggregate-related Industry Group components could 
result in localized improvement at certain intersections analyzed in the SEIR. However, the 
overall number of vehicle trips would not decrease, and truck traffic would likely increase, 
compared to the project, because there would be an increase in the volume of raw aggregate that 
would have to be trucked from the Islais Creek area to production facilities - assuming that there 
would be a shift in the import to San Francisco of these raw aggregates from truck transport to 
ship transport. As stated on pp. A.2-A.3 of SEIR Appendix A, "This shift is anticipated to be 
induced by declining reserves in local quarries, and would be facilitated by the proposed 
waterside locations of the Industry Group members. That is, the proposed project sites were 
selected, in part, to allow for direct import of sand, gravel, and crushed rock in the future." 

The SEIR does include Alternative B, p. 169, which would not include development of any 
asphalt plants in the project area (because asphalt production would not represent either a 
relocation of an existing use or a strictly maritime use, even though aggregate would be imported 
by ship). This alternative also does not include the proposed bus storage and maintenance 
facility at Pier 96, which would not be a maritime use, although it would be consistent with the 
Port's objective to increase productivity of its land through interim use. However, because of the 
maritime nature of many of the project components and of much of the project area, because of 
the limited supply of large parcels of industrial land, particularly those that can accommodate 
both marine and rail transport, and because little, if any, reduction in unmitigable effects would 
be likely, the SEIR does not consider other alternatives that do not include the aggregate-related 
facilities at their proposed locations within the project area. 

The only other significant, unavoidable effects identified in Chapter V of the SEIR - beyond 
those related to Air Quality - would be degradation in level of service at certain local 
intersections. However, these impacts would not occur until implementation of Phase II of the 
project, assumed by 2015. These traffic impacts would be reduced or eliminated if portions of 
Phase II were to be eliminated from the project. However, as noted in the response to 
Comment H-1, p. C&R. 38, of the future development assumed in the SEIR, a large portion - 
that on the Pier 90-94 backlands - was assumed to occur on land currently designated for 
maritime use. Thus, the development assumptions used in the SEIR transportation analysis 
would entail major changes in the planning framework and in land uses. The Port plans further 
study to determine whether non-maritime use is feasible on the Pier 90-94 backlands; the SEIR 
assumed office and/or research and development uses to provide a general understanding of 
environmental impacts at a very conceptual level, to inform the planning study for this area. 



Case No. 1999.377E 



C&R. 104 

ESA 990267 



Southern Waterfront SEIR 



To: 



Froin: 



Re: 



Hillary Gitelman 
Environmental Review 

SAN F^NCISCO PLANNING DEPARTMENT 
Fax: 415 558 6409 

Robin Chiang 
President 

Friends of Islais Creek 

PORSOF SAN FRANCISCO 
NEWBUSINESSES AT CONTAINER FACILrTY 
NEW RJJNOIS STREET BRIDGE 



FRIENDS OF ISLAJS CRSI^ 

6 Hillview Court San Francisco $4^24:; 

RECEIVED • .4 




PL.^J\iNiNG DEPT 



Dear Ms Gitelnian: . ..- 'r-?./ ' '^ 

Friends of Islais Creek has worked closely and in harmony with BCDC and the Port of: 
San Francisco for nearly 1 3 years in the vicinity of the Port" s Container Facility. '--M 

We have worked to bring public access to islais Creek and to help make the area arcyurifi. 
it cleaner, safer, and iT(ore wekx)nmng. 

We celebrate this as one of the few remaining industrial enclaves in the City. While we 
encourage new people moving to the area we hope they respect the need for long 
established industries to continue while they remain economically viable. 

We support the establishment of new industries on Port properties — some of whk:h4iiav^| 
been forced to move from Mission Bay. We believe the aggregation of such uses in'^iiis^^ 
location could realize the benefits to environment, to employment and to the cost of ; . f v 
doing business in the City that have been daimed. 

We also support the Port's proposal to build a second bridge over Islais Creek as arf ? #S 
extension of Illinois Street But we hope the Port will respect the fragile and complest 
industrial aesthetic that we have wori^ed hard to maintain with existing stnjctures and 
nurture in new projects. We want the new bridge to be visually compatible with the spiiiti 
of Islais Creek — especially in view of our work, years ago, to name the 3*^ Street bridge > 
after its engineer Lavon Nishkian. 

In addition, we agree with the Coast Guard and Army Corps that the new Illinois Street - 
bridge shouki not prevent Islais Creek from remaining a navigable watenvay-Hnduding i 
the west end of the Creek. The need to navigate the Creek may not happen within ihe 
next few years, but we feel the new bridge should be designed to accomrrKxlate future |r 
modification that will make it as easily operable as the existing Nishkian Bridge. M. 

Feel free to call me if you have any questions: 415 995 9870. Thank you. 



Sincere(y, 




Case No. 1999.377 E 



C&R.105 

ESA 990267 



VIII. SUMMARY OF COMMENTS AND RESPONSES 



C. WRITTEN COMMENTS AND RESPONSES 



LETTER L - FRIENDS OF ISLAIS CREEK 



L-1) The comments concern one of the project components, the proposed Illinois Street bridge, and do 
not address the adequacy or accuracy of the SEIR. For information, it is noted that the SEIR 
states, on p. 22, that the Port of San Francisco "believes the navigational needs of the west end of 
Islais Creek are and will continue to be for small vessels." 



Case No. 1999.377E 



C&R.106 

ESA 990267 



Southern Waterfront SEIR 




Golden Gate Audubon Society 

2530 San Pablo Avenue, Suite G • Berkeley, California 94702 

Phone:(510) 843-2222 • Fax:(510)843-5351 • Email: ggas@compuserve.coni 

Americans Committed to Conservation • A Chapter of the National Audubon Society 



® 



November 7,2000 RECEEVED 

^''^'^ RECEIVED ^OV-9 20flO 

Environmental Review Officer . • ^: ' vTv ^ s 

1660 Mission Street, Suite 500 NUV 1 o ZUUU .f'-T" 

San Francisco, CA 94103 PUNNING DEPT 

Re: Comments on: San Francisco Southern Waterfront Draft Supplemental 
Envirormiental Impact Report (Case No. 1 999.3 77E) 

Gentlemen/Ladies : 

Once again. Golden Gate Audubon Society is concerned that the environmental 
review process for the Waterfront does not adequately address impacts of proposed 
development on biological resources. 

In commenting on the draft EIR for the Waterfront Land Use Plan in 1996, we noted 
that wildlife and the habitat it requires were given short shrift in those documents. The 
official response stated in part: 

... the WLUP EIR is a Program EIR . . . and as such is not intended to 
provide an exhaustive list of non-special-status plant and animal species in 
the project area, nor is it the intent that the EIR analyze impacts at a 
project level of detail. Subsequent development proposals ... would be 
subject to subsequent project-specific environmental review, which could 
involve, among other issues, further site-specific review of plant and 
animal species once a particular development proposal were advanced. ... 

[1997 Final EIR, C&R.96] 

The current SEIR purports to be project-specific for cargo shipping at Piers 80 and 
94-96 and Port dredge material handling at Pier 94 — and presumably for the Industry 
Group components and the Illinois St. Bridge; any other programs or projects in the study 
area are said to be "subject to additional project-specific environmental review." [SEIR, 
S-7] 

In Section III.F, on potential impacts on biological resources, the SEIR focuses 
almost entirely on the proposed Illinois St, Bridge, with a reference to the 1997 Final EIR 
for information on "other effects" and to itSLOwn discussion of storm water runoff. 



M-l 



Case No. } 999. 3 77 E 



C&R.107 

ESA 990267 



Southern Waterfront SEIR 



Page 2 



[SEIR, 1 36, 141 ] As to the BPA temiinal and the Port's dredge material facility, it 
merely states that neither "would encroach into the existing wetlands." [SEIR, 141] 

Thus, except for the focus on the Illinois St. Bridge, there is still no discussion of 
"wildlife and the habitat it requires," our expressed concem in 1996. And specifically, 
there is no real discussion of impacts on the Pier 94 wetlands (at Seawall Lot 352) or on 
the Piers 90-94 Backlands. 



Has there been a delineation of the Pier 94 wetlands, on which the "no encroachment" 
conclusion is based? As seen in the attached photographs (taken by Alex Schwarz in 
1990), the wetland habitat between and adjacent to Piers 92 and 94 is substantial. 

The 1997 Final EIR noted that wetlands could be adversely affected by public access, 
a truism that the SEIR apparently limits to members of the general public. What about 
intrusions, for example, by BPA employees and contractors? Shouldn't there be buffer 
zones for protection of the Pier 94 wetlands? and (since the general public is excluded) 
oversight measures to assure there are in fact no physical intrusions? 

What about physical intrusions fi*om shipping for the BPA operations and any future 
cargo shipping? Would vessels alter the wetlands, either directly or by wake 
displacement? And what about non-physical intrusions, such as noise and night lighting 
from adjacent industrial operations? These may have significant impacts on waterbirds 
using the wetland habitats. 

The Waterfront Plan states that "appropriate mitigation measures" would be required 
if development causes filling of the Pier 94 wetlands. [SEIR 141] Have any such 
mitigation measures been identified? Of course, the Port may not permit degradation of 
the wetlands from interim uses merely because it may propose mitigation measures in the 
fiiture. And there should be provision for reasonable access to the wetlands for research 
and stewardship purposes. 

In fact, there is no survey of biological resources in the Piers 90-94 area (except for 
the limited focus on the Illinois St. Bridge), and thus no basis for an adequate discussion 
of impacts of development on those resources. What plant and animal species inhabit the 
Pier 94 wetlands? The Piers 90-94 Backlands? Nothing in the SEIR or the referenced 
sections of the 1997 Final EIR answers those questions. 

For example, the 1997 Final EIR merely states ~ for the entire Waterfront - that 
terrestrial vegetation outside wetlands is largely limited to "weeds" on vacant sites and 
some planted omamentals. It contains a brief reference to birds ~ again along the entire 
Wateitont ~ and appends a list of "typical" birds in its Appendix G. [1997 Final EIR, 
244-245] 

Terrestrial vegetation in the area south of Islais Creek (both the site mapped as "Pier 
90-94 Backlands" in SEIR Figure 2 and the "white" areas north and northeast of it) is not 
limited to "weeds and omamentals." Native plants there include toyon (Heteromeles 



Case No. 1999. 377 E 



C&R.108 

ESA 990267 



Southern Woierfront SEIR 



Page 3 



arbutifolia) and coyote bush (Baccharis pilularis), both of which are important food 
plants for a number of wildlife species, both vertebrate and invertebrate. Many 
introduced species also have high value for native wildlife. 

We know of two bird species that may be found in the study area that are federal and 
state species of concern: the Burrowing Owl and the Tricolored Blackbird. Specifically, 
Burrowing Owls have been seen at the east end of Cesar Chavez St., at Hunters Point 
Shipyard and at Candlestick Point Park, and vacant land such as the Piers 90-94 
Backlands would provide suitable habitat for them. 

The Port's dredge material storage facility, as well as future uses of the "Backlands" 
site, will clearly displace habitat, and that impact should be assessed. If this SEIR is not 
the appropriate document for such an assessment, please name the documents in which it 
will be done, and please be svu-e that the Golden Gate Audubon Society is on the mailing 
list to receive them. 

This project may not only have significant impacts upon wildlife, but also upon the 
human inhabitants of this section of the City. The siting of two asphalt plants, two or 
three concrete batching plants, the importation and storage of construction aggregates, a 
construction materials recycler and a bus yard are all being proposed for the 
Bayview/Hunters Point area that is already the home to a power plant and the Southeast 
Sewage Treatment Plant, the Port lands and many other industries such as auto wrecker 
yards, etc. This EIR should address the issue of whether this community is being 
presented with an undue share of such potentially air, water and noise polluting 
industries. Has the EIR considered these impacts fi'om an environmental justice 
perspective? 

While we appreciate the fact that the storm water runoff will not be injected into the 
existing combined sewer system, we believe that the proposed treatment of this storm 
water runoff prior to Bay discharge could be improved. Constructed wetlands can provide 
significant water quality improvements to storm water runoff and in combination with 
wetlands designed for habitat can provide dual benefits to the community, clean water 
and recreational and educational benefits. 

In closing we wish to reiterate our great disappointment resulting fi-om the failure of 
this Draft Supplemental EIR to adequately address wetlands and wildlife issues. The 
nearly complete lack of attention to these issues makes this a fatally flawed document. 
We thank you for your attention to our concerns. 



Sincerely yours. 




Arthur Feinstein 
Executive Director 



Case No. 1 999.377 E 



C&R.109 

ESA 990267 



Southern V/aterfront SEIR 



VIII. SUMMARY OF COMMENTS AND RESPONSES 

C. WRITTEN COMMENTS AND RESPONSES 

LETTER M - GOLDEN GATE AUDUBON SOCIETY 

M-1) Please see the response to Comment H- 13, p. C&R.45. 

As noted in that response, there is an existing fence between the paved area of Pier 94 and the 
wetlands to the north, thus preventing any encroachment. Maritime activity at Pier 94 would 
constitute the continuation of ongoing actions, including ship travel and night lighting, which 
currently exists both north (Pier 80) and south (Piers 94-96) of the Pier 94 wetlands. Therefore, 
there would be no new effects. Effects of ships' wakes are limited because ships move 
extremely slowly in immediate vicinity of the piers. 

With regard to other existing and planned development in the project area, the SEIR includes 
cumulative analyses throughout the document. For more information, please see the responses to 
Comment 1-4 (cumulative increases in stormwater flow; p. C&R.64); Comment J-2 (cumulative 
traffic growth; p. C&R.79); and Comment K-6 (cumulative increases in criteria air pollutants; 
p. C&R.lOl). 

Effects of stormwater runoff are discussed on SEIR pp. 109-1 12. Regarding the increase in 
stormwater runoff, please see the response to Comment Letter I, and in particular, the response 
to Comment I-l, p. C&R.61. 

The SEIR is not flawed with regard to its discussion of biological resources, which are analyzed 
in Section III.F. As described in that section, the project would have limited effects with regard 
to biological resources, a conclusion that is reinforced by the Port's commitment to complete a 
wetlands delineation and biological survey(s) at Pier 94 prior to the implementation of any 
construction there, as described in the response to Comment H-13, p. C&R.45. 



Case No. 1999. 377 E 



C&R.lll 

ESA 990267 



Southern Waterfront SEIR 



Pier 70 Advisory Group 



October 25, 2000 

Ms. Hillary Gitelman 
Environmental Review Officer 

Planning Department, City and County of San Francisco 
1660 Mission Street 
San Francisco, CA 94103-2414 

Dear Ms. Gitelman: 

This response to the Draft SEIR has been drafted on behalf of the Pier 70 Advisory Group by 
Toby Levine and John Borg, co-chairs of the group. The Pier 70 Advisory Group is a diverse 
collection of 25 citizens with varied interests in the future of Pier 70 and the surrounding Central 
Waterfront and Southern Waterfront districts. The group was appointed by the Port of San 
Francisco and approved by the Port Commission, in March 2000, to provide community input 
and help in drafting development guidelines for the Port's 16-acre Pier 70 Opportunity Area. The 
comments detailed herein are directed on the area of study as a whole. However, because we have 
spent extensive time studying the Pier 70 area, which is somewhat removed from the bulk of 
proposed new uses, our comments are most notably directed on impacts to Pier 70, its 
surrou